HomeMy WebLinkAboutPB Packet 2025-03-18TOWN OF ITHACA PLANNING BOARD
Shirley A. Raffensperger Board Room, Town Hall
215 North Tioga Street
Ithaca, New York 14850
Tuesday, March 18, 2025 6:30 P.M.
AGENDA
1. Persons to be heard.
2. SEQR Determination: Consideration of a SEQR determination for the proposed Cornell Game Farm
Road Field Hockey Field project on Game Farm Road, located immediately east of the existing
Cornell soccer fields. The proposal involves constructing new field hockey facilities in two phases,
with phase one including the conversion of the existing grass practice field into a synthetic turf field
along with construction of a new driveway, formalized parking area, pedestrian amenities, and two
support facilities (a 1,700 +/- square foot rest room/team room building, and a 480 +/- square foot
press box). Phase two involves the construction of a clubhouse for the field hockey team, with locker
rooms, meeting rooms, physical therapy rooms, lounge, toilets, showers, and indoor synthetic turf
training space. Phase two is projected to be constructed within five years of the athletic field
installation. The project also includes new lighting, landscaping, stormwater facilities, and other site
improvements. The project is a Type I Action under the State Environmental Quality Review Act
and is subject to environmental review. The Planning Board established itself as the Lead Agency in
the environmental review of the project at the January 7, 2025, Planning Board meeting. Cornell
University, Owner/Applicant; Kimberly Van Leeuwen, Fisher Associates, Applicant/Agent.
3. Approval of Minutes.
4. Other Business.
5. Adjournment.
C.J. Randall
Director of Planning
607-273-1747
Members of the public are welcome to attend meetings in person at Town Hall or virtually via Zoom videoconference at
https://us06web.zoom.us/j/83643764382 or by calling (929) 436-2866 and entering Meeting ID: 836 4376 4382. The public will have
an opportunity to see and hear the meeting live and provide comments directly to the Board during Persons to be Heard and/or Public
Hearing.
To watch the meeting live, please visit www.youtube.com/channel/UCC9vycXkJ6klVIibjhCy7NQ/live.
Recorded meetings are viewable at YouTube.com/TownofIthacaVideo.
Written comments can be addressed to the Planning Board (in-person at Town Hall; by mail; or via email at
Planning@townithacany.gov) until noon the day of the meeting. Comments addressed to the Board will be distributed to all Board
members and Applicant(s). Comments received after the posting of the agenda packet (five business days prior to the meeting) are
distributed to the Board on the day of the meeting. Comments are public and become part of the project file.
Applications and associated project materials are available on the Town’s website at https://townithacany.gov/meeting-calendar-
agendas/ under the calendar meeting date.
1
PLANNING DEPARTMENT MEMORANDUM
TO: Planning Board Members
FROM: Christine Balestra, Senior Planner
DATE: March 11, 2025
RE: Cornell Game Farm Rd Field Hockey Field – SEQR Determination
Enclosed please find a completed Full Environmental Assessment Form (FEAF), Parts 1-3 with
attachments (Part 1 completed by the applicant), along with a draft SEQR resolution for the Cornell
Game Farm Road Field Hockey Field project. Please note that the FEAF references documents and
studies that the Planning Board reviewed at their 11/19/24, 1/7/25, and 3/4/25 Planning Board
meetings.
The Town of Ithaca Planning Board established themselves as the Lead Agency in the environmental
review of the project on January 7, 2025. After a discussion, the Board asked the applicant and staff
to prepare and provide additional research to assist them in making an environmental
determination. These additional materials were provided to the board and were discussed at the
March 4, 2025, meeting.
The purpose of the March 18, 2025, Planning Board meeting is for the Board to review the attached
materials, make any changes and modifications as necessary, and render an environmental
determination for the Game Farm Road Field Hockey Field project.
Please feel free to contact me if you have questions regarding this proposal by phone at 273-1721,
extension 121, or by email at cbalestra@townithacany.gov.
Cc: Elisabete Godden, Project Manager, Cornell University, Facilities and Campus Services
Leslie Schill, Director of Campus Planning, Cornell University, Office of the University Architect
Kimberly Van Leeuwen, Director of Landscape Architecture, Fisher Associates
Page 1 of 2
PROPOSED RESOLUTION: SEQR
Cornell Game Farm Road Field Hockey Field Project
Tax Parcel No.’s 62.-2-4, 62.-2-5, 62.-2-6
Game Farm Road
Town of Ithaca Planning Board
March 18, 2025
WHEREAS:
1. This action involves consideration of a SEQR determination for the proposed Cornell Game Farm
Road Field Hockey Field project on Game Farm Road, located immediately east of the existing
Cornell soccer fields. The proposal involves constructing new field hockey facilities in two phases,
with phase one including the conversion of the existing grass practice field into a synthetic turf
field along with construction of a new driveway, formalized parking area, pedestrian amenities, and
two support facilities (a 1,700 +/- square foot restroom/team room building, and a 480 +/- square
foot press box). Phase two involves the construction of a clubhouse for the field hockey team, with
locker rooms, meeting rooms, physical therapy rooms, lounge, toilets, showers, and indoor
synthetic turf training space. Phase two is projected to be constructed within five years of the
athletic field installation. The project also includes new lighting, landscaping, stormwater facilities,
and other site improvements. Cornell University, Owner/Applicant; Kimberly Van Leeuwen,
Fisher Associates, Applicant/Agent;
2. The proposed project, which requires Site Plan approval and Special Permit by the Planning Board,
is a Type I action pursuant to the State Environmental Quality Review Act, 6 NYCRR Part 617,
and Chapter 148 of the Town of Ithaca Code regarding Environmental Quality Review, because the
proposal involves an activity, other than the construction of residential facilities, that involves the
physical alteration of 10 acres (6 NYCRR 617.4 (b) (6) (i)), and parking for 100 vehicles (Town
Code 148-5.C (3));
3. At its meeting on November 19, 2024, the Town of Ithaca Planning Board (1) reviewed a Full
Environmental Assessment Form, Part 1, submitted by the applicant, along with a report containing
a narrative and studies titled “Game Farm Road Field Hockey Field, Site Plan Review Application
Report,” dated October 3, 2024, prepared by Fisher Associates, drawings titled “Game Farm Road
Field Hockey Field, Cornell University,” dated 09-27-2024, prepared by Sasaki, and other
materials; and (2) proposed to establish itself as the Lead Agency to coordinate the environmental
review of the above-referenced proposal. Potential Involved and Interested agencies were notified
of its intent to serve as Lead Agency on November 20, 2024;
4. The Planning Board, having received no objections from other Involved Agencies, on January 7,
2025, established itself as Lead Agency to coordinate the environmental review of the above-
described proposal;
5. The Planning Board, on March 18, 2025, has accepted as adequate the Full Environmental
Assessment Form Part 1, submitted by the applicant, Parts 2 and 3, prepared by Town Planning
staff, the materials noted in Whereas #3 above; additional materials in a binder titled “Game Farm
Road Field Hockey Field Supplemental Materials Submission,” dated January 31, 2025, prepared
by Fisher Associates; additional supplemental materials in a binder titled “Game Farm Road Field
Hockey Field Supplemental Materials Submission,” dated February 21, 2025, prepared by Fisher
Associates; and other materials;
Page 2 of 2
6. The Town Planning staff has recommended a negative determination of environmental significance
with respect to the proposal;
NOW THEREFORE BE IT RESOLVED:
That the Town of Ithaca Planning Board hereby makes a negative determination of environmental
significance in accordance with Article 8 of the Environmental Conservation Law and 6 NYCRR Part
617 New York State Environmental Quality Review for the above referenced proposal, based on the
information in the Full EAF Part 1 and for the reasons set forth in the Full EAF Parts 2 and 3, and,
therefore, a Draft Environmental Impact Statement will not be required.
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Full Environmental
Assessment Form
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FEAF 2019
Full Environmental Assessment Form
Part 1 - Project and Setting
Instructions for Completing Part 1
Part 1 is to be completed by the applicant or project sponsor. Responses become part of the application for approval or funding,
are subject to public review, and may be subject to further verification.
Complete Part 1 based on information currently available. If additional research or investigation would be needed to fully respond to
any item, please answer as thoroughly as possible based on current information; indicate whether missing information does not exist,
or is not reasonably available to the sponsor; and,when possible, generally describe work or studies which would be necessary to
update or fully develop that information.
Applicants/sponsors must complete all items in Sections A & B. In Sections C, D & E, most items contain an initial question that
must be answered either “Yes”or “No”. If the answer to the initial question is “Yes”, complete the sub-questions that follow. If the
answer to the initial question is “No”,proceed to the next question. Section F allows the project sponsor to identify and attach any
additional information. Section G requires the name and signature of the applicant or project sponsor to verify that the information
contained in Part 1is accurate and complete.
A.Project and Applicant/Sponsor Information.
Name of Action or Project:
Project Location (describe, and attach a general location map):
Telephone:
E-Mail:
Address:
City/PO: State: Zip Code:
Project Contact (if not same as sponsor; give name and title/role): Telephone:
E-Mail:
Address:
City/PO: State: Zip Code:
Property Owner (if not same as sponsor): Telephone:
E-Mail:
Address:
City/PO: State: Zip Code:
Page 1 of 13
Cornell Field Hockey field
On the west side of Game Farm Road, between the road and McGovern Fields; Town Parcel #62.-2-6 and #62.-2-5
607.227.1400
kmichaels@fisherassoc.com
1001 W. Seneca Street, Suite 201
Ithaca NY 14850
Elisabete Godden, Project Manager
607.255.2478
egodden@cornell.edu
102 Humphries Service Building
Ithaca NY 14853
Cornell University
Ithaca NY 14850
Brief Description of Proposed Action (include purpose or need):
Cornell University is proposing to construct facilities for varsity field hockey at their Game Farm Road lands utilized for athletics. Construction of the project is proposed in two
phases. Phase one will provide Cornell’s field hockey athletes with a NCAA-compliant synthetic turf field. The field is proposed on the site of an existing grass athletic field next
to two improved grass soccer fields known as McGovern Fields. Phase one will include a field hockey pitch, a new driveway, formalized parking, pedestrian amenities, and
small support facilities. The support facilities include a four-restroom building and a press box building.
Phase two, which involves an additional building, is anticipated to move forward within five years of the athletic field installation. The proposed building will be a single-story
clubhouse facility to serve the field hockey team. The clubhouse will include team locker rooms, offices, meeting rooms, a physical therapy/training room, a lounge, toilets,
showers, and an indoor training space. The indoor training space will have a synthetic turf floor surface that matches the turf used for the exterior field hockey field and will be
used for field hockey practice during inclement weather.
The proposed septic system, storm water management system, and electrical transformer included in the Phase one construction will be sized to accommodate the needs of
the future clubhouse. The enclosed documents and FEAF address the full project buildout (Phases one and two).
Name of Applicant/Sponsor:
Kimberly Van Leeuwen
and #62-2-4
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B.Government Approvals
B.Government Approvals, Funding, or Sponsorship. (“Funding” includes grants, loans, tax relief, and any other forms of financial
assistance.)
Government Entity If Yes: Identify Agency and Approval(s)
Required
Application Date
Actual or projected)
a.City Council, Town Board,9 Yes 9 No
or Village Board of Trustees
b. City, Town or Village 9 Yes 9 No
Planning Board or Commission
c. City, Town or 9 Yes 9 No
Village Zoning Board of Appeals
d.Other local agencies 9 Yes 9 No
e. County agencies 9 Yes 9 No
f. Regional agencies 9 Yes 9 No
g.State agencies 9 Yes 9 No
h. Federal agencies 9 Yes 9 No
i. Coastal Resources.
i. Is the project site within a Coastal Area, or the waterfront area of a Designated Inland Waterway?9 Yes 9 No
ii. Is the project site located in a community with an approved Local Waterfront Revitalization Program?9 Yes 9 No
iii. Is the project site within a Coastal Erosion Hazard Area?9 Yes 9 No
C.Planning and Zoning
C.1. Planning and zoning actions.
Will administrative or legislative adoption, or amendment of a plan, local law, ordinance, rule or regulation be the 9 Yes 9 No
only approval(s) which must be granted to enable the proposed action to proceed?
If Yes, complete sections C, F and G.
If No, proceed to question C.2 and complete all remaining sections and questions in Part 1
C.2. Adopted land use plans.
a. Do any municipally- adopted (city, town, village or county) comprehensive land use plan(s) include the site 9 Yes 9 No
where the proposed action would be located?
If Yes, does the comprehensive plan include specific recommendations for the site where the proposed action 9 Yes 9 No
would be located?
b.Is the site of the proposed action within any local or regional special planning district (for example: Greenway;9 Yes 9 No
Brownfield Opportunity Area (BOA); designated State or Federal heritage area; watershed management plan;
or other?)
If Yes, identify the plan(s):
c. Is the proposed action located wholly or partially within an area listed in an adopted municipal open space plan,9 Yes 9 No
or an adopted municipal farmland protection plan?
If Yes, identify the plan(s):
Page 2 of 13
Future Land Use designation is "campus")
Town Board: Sewer Exemption
Town Planning Board: SEQR, Site Plan Approval,
Special Use Permit
ZBA: Variance(s)
NYSDEC: Stormwater Permit; SPDES Permit
10/3/2024
3/10/2025
TBD
TC OWTS Permit TBD
TC GML letter received 11/26/2024
TCHD Onsite Wastewater Treatment System (OWTS)
Construction Permit; TC GML 239 Review/Referral
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C.3. Zoning
a.Is the site of the proposed action located in a municipality with an adopted zoning law or ordinance.9 Yes 9 No
If Yes, what is the zoning classification(s) including any applicable overlay district?
b.Is the use permitted or allowed by a special or conditional use permit?9 Yes 9 No
c. Is a zoning change requested as part of the proposed action?9 Yes 9 No
If Yes,
i.What is the proposed new zoning for the site? ___________________________________________________________________
C.4. Existing community services.
a. In what school district is the project site located? ________________________________________________________________
b. What police or other public protection forces serve the project site?
d.What parks serve the project site?
D.Project Details
D.1. Proposed and Potential Development
a.What is the general nature of the proposed action (e.g., residential, industrial, commercial, recreational; if mixed, include all
components)?
b.a. Total acreage of the site of the proposed action?
b.Total acreage to be physically disturbed?
c. Total acreage (project site and any contiguous properties) owned
or controlled by the applicant or project sponsor?
c. Is the proposed action an expansion of an existing project or use?9 Yes 9 No
i.If Yes, what is the approximate percentage of the proposed expansion and identify the units (e.g., acres, miles, housing units,
square feet)? % ____________________ Units: ____________________
d.Is the proposed action a subdivision, or does it include a subdivision?9 Yes 9 No
If Yes,
i.Purpose or type of subdivision? (e.g., residential, industrial, commercial; if mixed, specify types)
ii.Is a cluster/conservation layout proposed?9 Yes 9 No
iii.Number of lots proposed? ________
iv.Minimum and maximum proposed lot sizes? Minimum __________ Maximum __________
e.Will the proposed action be constructed in multiple phases?9 Yes 9 No
i.If No, anticipated period of construction: _____ months
ii.If Yes:
Total number of phases anticip _____ated
Anticipated commencement date of phase 1 (including demolition) _____ month _____ year
Anticipated completion date of final phase _____ month _____year
Generally describe connections or relationships among phases, including any contingencies where progress of one phase may
determine timing or duration of future phases: _______________________________________________________________
Page 3 of 13
LDR - Low Density Residential
Ithaca City School District
Cornell Campus Police, Tompkins County Sheriff
East Hill Recreation Way
Recreational - Field Hockey Field
2
3 2025
tbd tbd
It is anticipated that within five years, the phase two building could move forward.
If so, it would likely take 12-18 months to complete. The infrastructure proposed for phase I is sized to accommodate phase II.
c. Which fire protection and emergency medical services serve the project site?
It_h _a _c _a _F _ir _e Department, __Ba_n _g _s __A _m _b _ul _a _n _c _e
123 _+ _/-___1_5 _. _65 acres
1_2 _. _22 acres
5 _06 acres
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f. Does the project include new residential uses?9 Yes 9 No
If Yes, show numbers of units proposed.
One Family Two Family Three Family Multiple Family (four or more)
Initial Phase
At completion
of all phases
g. Does the proposed action include new non-residential construction (including expansions)?9 Yes 9 No
If Yes,
i. Total number of structures ___________
ii.Dimensions (in feet) of largest proposed structure: ________height; ________width; and _______ length
iii.Approximate extent of building space to be heated or cooled: ______________________ square feet
h. Does the proposed action include construction or other activities that will result in the impoundment of any 9 Yes 9 No
liquids, such as creation of a water supply, reservoir, pond, lake, waste lagoon or other storage?
If Yes,
i.Purpose of the impoundment: ________________________________________________________________________________
ii.If a water impoundment, the principal source of the water: 9 Ground water 9 Surface water streams 9 Other specify:
iii.If other than water, identify the type of impounded/contained liquids and their source.
iv.VoApproximatesizeoftheproposedimpoundment.lume: ____________ million gallons; surface area: ____________ acres
v.________ height; _______ lengthDimensionsoftheproposeddamorimpoundingstructure:
vi.Construction method/materials for the proposed dam or impounding structure (e.g., earth fill, rock, wood, concrete):
D.2. Project Operations
a. Does the proposed action include any excavation, mining, or dredging, during construction, operations, or both? 9 Yes 9 No
Not including general site preparation, grading or installation of utilities or foundations where all excavated
materials will remain onsite)
If Yes:
i .What is the purpose of the excavation or dredging? _______________________________________________________________
ii.How much material (including rock, earth, sediments, etc.) is proposed to be removed from the site?
Volume (specify tons or cubic yards): ____________________________________________
Over what duration of time? ____________________________________________________
iii.Describe nature and characteristics of materials to be excavated or dredged, and plans to use, manage or dispose of them.
iv.Will there be onsite dewatering or processing of excavated materials? 9 Yes 9 No
If yes, describe. ___________________________________________________________________________________________
v.What is the total area to be dredged or excavated? _____________________________________acres
vi.What is the maximum area to be worked at any one time? _______________________________ acres
vii.What would be the maximum depth of excavation or dredging? __________________________ feet
viii.Will the excavation require blasting?9 Yes 9 No
ix.Summarize site reclamation goals and plan: _____________________________________________________________________
b. Would the proposed action cause or result in alteration of, increase or decrease in size of, or encroachment 9 Yes 9 No
into any existing wetland, waterbody, shoreline, beach or adjacent area?
If Yes:
i.Identify the wetland or waterbody which would be affected (by name, water index number, wetland map number or geographic
description): ______________________________________________________________________________________________
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3
20'-0"97'-0"165'-0"
14,400
Stormwater detention and treatment
N/A
N/A
1.0 0.72
5'-14'375'
Traditional construction techniques associated with the installation of a compacted earth fill embankment for stormwater mitigation
Project does NOT include an "impoundment" per NYS DEC definition, just standard stormwater management facilities
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ii.Describe how the proposed action would affect that waterbody or wetland, e.g. excavation,fill, placement of structures, or
alteration of channels,banks and shorelines.Indicate extent of activities, alterations and additions in square feet or acres:
iii.Will the proposed action cause or result in disturbance to bottom sediments?Yes 9 No
If Yes,describe: __________________________________________________________________________________________
iv.Will the proposed action cause or result in the destruction or removal of aquatic vegetation? 9 Yes 9 No
If Yes:
acres of aquatic vegetation proposed to be removed: ___________________________________________________________
expected acreage of aquatic vegetation remaining after project completion:________________________________________
purpose of proposed removal (e.g. beach clearing, invasive species control, boat access): ____________________________
proposed method of plant removal: ________________________________________________________________________
if chemical/herbicide treatment will be used, specify product(s): _________________________________________________
v.Describe any proposed reclamation/mitigation following disturbance: _________________________________________________
c.Will the proposed action use, or create a new demand for water?9 Yes 9 No
If Yes:
i.Total anticipated water usage/demand per day: __________________________ gallons/day
ii.Will the proposed action obtain water from an existing public water supply?9 Yes 9 No
If Yes:
Name of district or service area: _________________________________________________________________________
Does the existing public water supply have capacity to serve the proposal?9 Yes 9 No
Is the project site in the existing district?9 Yes 9 No
Is expansion of the district needed?9 Yes 9 No
Do existing lines serve the project site?9 Yes 9 No
iii.Will line extension within an existing district be necessary to supply the project?9 Yes 9 No
If Yes:
Describe extensions or capacity expansions proposed to serve this project: ________________________________________
Source(s) of supply for the district: ________________________________________________________________________
iv.Is a new water supply district or service area proposed to be formed to serve the project site?9 Yes 9 No
If, Yes:
Applicant/sponsor for new district: ________________________________________________________________________
Date application submitted or anticipated: __________________________________________________________________
Proposed source(s) of supply for new district: _______________________________________________________________
v.If a public water supply will not be used, describe plans to provide water supply for the project: ___________________________
vi.If water supply will be from wells (public or private),what is the maximum pumping capacity: _______ gallons/minute.
d. Will the proposed action generate liquid wastes?9 Yes 9 No
If Yes:
i.Total anticipated liquid waste generation per day: _______________ gallons/day
ii.Nature of liquid wastes to be generated (e.g., sanitary wastewater, industrial; if combination, describe all components and
approximate volumes or proportions of each): __________________________________________________________________
iii.Will the proposed action use any existing public wastewater treatment facilities? 9 Yes 9 No
If Yes:
Name of wastewater treatment plant to be used: _____________________________________________________________
Name of district: ______________________________________________________________________________________
Does the existing wastewater treatment plant have capacity to serve the project?9 Yes 9 No
Is the project site in the existing district?9 Yes 9 No
Is expansion of the district needed?9 Yes 9 No
Page 5 of 13
950 Domestic consumption only)
Cornell University Water System (NYSDEC Permit #: 7-5030-00008/00007)
A new 8" HDPE water main will be connected to the existing system located at the McGovern Soccer Building and extended to the project.
Fall Creek via the Cornell University Water Filtration Plant
N/A
N/A
N/A
A public water supply will be used for the proposed project.
N/A
950
Sanitary wastewater
N/A
N/A
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Do existing sewer lines serve the project site?9 Yes 9 No
Will a line extension within an existing district be necessary to serve the project?9 Yes 9 No
If Yes:
Describe extensions or capacity expansions proposed to serve this project: ____________________________________
iv.Will a new wastewater (sewage) treatment district be formed to serve the project site?9 Yes 9 No
If Yes:
Applicant/sponsor for new district: ____________________________________________________________________
Date application submitted or anticipated: _______________________________________________________________
What is the receiving water for the wastewater discharge? __________________________________________________
v.If public facilities will not be used, describe plans to provide wastewater treatment for the project, including specifying proposed
receiving water (name and classification if surface discharge or describe subsurface disposal plans):
vi.Describe any plans or designs to capture, recycle or reuse liquid waste: _______________________________________________
e.Will the proposed action disturb more than one acre and create stormwater runoff, either from new point 9 Yes 9 No
sources (i.e. ditches, pipes, swales, curbs, gutters or other concentrated flows of stormwater) or non-point
Will stormwater runoff flow to adjacent properties?9 Yes 9 No
iv.Does the proposed plan minimize impervious surfaces, use pervious materials or collect and re-use stormwater?9 Yes 9 No
f.Does the proposed action include, or will it use on-site,one or more sources of air emissions, including fuel 9 Yes 9 No
combustion, waste incineration, or other processes or operations?
If Yes, identify:
i.Mobile sources during project operations (e.g., heavy equipment, fleet or delivery vehicles)
ii.Stationary sources during construction (e.g., power generation, structural heating, batch plant, crushers)
iii.Stationary sources during operations (e.g., process emissions, large boilers, electric generation)
g.Will any air emission sources named in D.2.f (above), require a NY State Air Registration, Air Facility Permit,9 Yes 9 No
or Federal Clean Air Act Title IV or Title V Permit?
If Yes:
i.Is the project site located in an Air quality non-attainment area? (Area routinely or periodically fails to meet 9 Yes 9 No
ambient air quality standards for all or some parts of the year)
ii.In addition to emissions as calculated in the application, the project will generate:
Tons/year (short tons) of Carbon Dioxide (CO2)
Tons/year (short tons) of Nitrous Oxide (N2O)
Tons/year (short tons) of Perfluorocarbons (PFCs)
Tons/year (short tons) of Sulfur Hexafluoride (SF6)
Tons/year (short tons) of Carbon Dioxide equivalent of Hydroflourocarbons (HFCs)
Tons/year (short tons) of Hazardous Air Pollutants (HAPs)
Page 6 of 13
N/A
A septic system that includes a subsurface mound absorption bed, septic tank, and pump station will be installed to provide wastewater treatment for the project.
The required onsite wastewater treatment system construction permit will be applied for and obtained from the Tompkins County Health Department.
N/A
source (i.e. sheet flow) during construction or post construction?
If Yes:
i.How much impervious surface will the project create in relation to total size of project parcel?
Square feet or ___3._4 _7 acres (add'l impervious surface)
Square feet or ___1 _2 _3 acres (parcel size)
ii. Describe types of new point sources. _D_ri _v _e _w _a _y/_p _a _rk_i _n _g _dr_a _i _na_g _e _s_y _st_e __m, _s__wa_l _es_, _a _t _hl _et _ic_f _i _el _d _u _n _d _er _d _r _ai _n _s _________________________
iii. Where will the stormwater runoff be directed (i.e. on-site stormwater management facility/structures, adjacent properties,
groundwater, on-site surface water or off-site surface waters)?
Ru_n _o _ff __wil_l _b _e _c _o _ll _e _ct _e _d _vi _a __a _s _ys_t _e _m _o_f _d _r _ai _n _a _g _e i _n _l _et _s, _s__wa_l _e _s, _a _n _d _u_n _d _e _r _dr _ai _n _s;_t _h _e _n _d _ir _e _ct _e _d _t _o _t _w _o _bi_o _r _et _e _nt_i _o _n f_il _t _er _s _a _n _d _a _n __ex _t _e _nd_e _d __de_t _e _nti_o _n
s _h _al _l _o _w _w _e _tl _a _n _d _b _ef_o _r _e _b _ei _n _g _r _el _e _a _s _e _d _to__C _a _s _ca _d _ill _a __Cr _e _e _k.__E _xi _st _i _ng__dr _a _in_a _g _e _p_a _tt _e _r _ns __a _nd_r _a _t _es__wi _ll _b _e __m _ai _n _t _ai _n _e _d. ______________________
If to surface waters, identify receiving water bodies or wetlands: ________________________________________________
C _a _s _c _ad_ill_a __C _re _e _k ________________________________________________________________________________________
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h.Will the proposed action generate or emit methane (including, but not limited to, sewage treatment plants,9 Yes 9 No
landfills, composting facilities)?
If Yes:
i.Estimate methane generation in tons/year (metric): ________________________________________________________________
ii. Describe any methane capture, control or elimination measures included in project design (e.g., combustion to generate heat or
electricity, flaring): ________________________________________________________________________________________
i.Will the proposed action result in the release of air pollutants from open-air operations or processes, such as 9 Yes 9 No
quarry or landfill operations?
If Yes: Describe operations and nature of emissions (e.g., diesel exhaust, rock particulates/dust):
j.Will the proposed action result in a substantial increase in traffic above present levels or generate substantial 9 Yes 9 No
new demand for transportation facilities or services?
If Yes:
i.When is the peak traffic expected (Check all that apply): Morning Evening Weekend
Randomly between hours of __________ to ________.
ii.For commercial activities only, projected number of truck trips/day and type (e.g., semi trailers and dump trucks): _____________
iii.ExistingParkingspaces:___________________Proposed ___________Net increase/decrease _____________________
iv.Does the proposed action include any shared use parking? Yes No
v.If the proposed action includes any modification of existing roads, creation of new roads or change in existing access, describe:
vi.Are public/private transportation service(s)or facilities available within ½ mile of the proposed site?9 Yes 9 No
vii Will the proposed action include access to public transportation or accommodations for use of hybrid, electric 9 Yes 9 No
or other alternative fueled vehicles?
viii.Will the proposed action include plans for pedestrian or bicycle accommodations for connections to existing 9 Yes 9 No
pedestrian or bicycle routes?
k.Will the proposed action (for commercial or industrial projects only) generate new or additional demand 9 Yes 9 No
for energy?
If Yes:
i.Estimate annual electricity demand during operation of the proposed action: ____________________________________________
ii.Anticipated sources/suppliers of electricity for the project (e.g., on-site combustion, on-site renewable, via grid/local utility, or
other):
iii.Will the proposed action require a new,or an upgrade, to an existing substation?9 Yes 9 No
l. Hours of operation. Answer all items which apply.
i.During Construction:ii.During Operations:
Monday - Friday: _________________________•Monday - Friday: ____________________________
Saturday: ________________________________•Saturday: ___________________________________
Sunday: _________________________________•Sunday: ____________________________________
Holidays: ________________________________•Holidays: ___________________________________
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N/A
7AM - 3PM
7AM - 3PM
7AM - 3PM
7AM - 3PM
6AM - 9PM
9AM - 9PM
9AM - 9PM
n/a
Project is not a commercial or industrial project
Although checked "no," please see parts 2 & 3
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m. Will the proposed action produce noise that will exceed existing ambient noise levels during construction,9 Yes 9 No
operation, or both?
If yes:
i.Provide details including sources, time of day and duration:
ii.Will the proposed action remove existing natural barriers that could act as a noise barrier or screen?9 Yes 9 No
Describe: _________________________________________________________________________________________________
n.Will the proposed action have outdoor lighting?9 Yes 9 No
If yes:
i.Describe source(s), location(s), height of fixture(s), direction/aim, and proximity to nearest occupied structures:
ii.Will proposed action remove existing natural barriers that could act as a light barrier or screen? 9 Yes 9 No
Describe: _________________________________________________________________________________________________
o.Does the proposed action have the potential to produce odors for more than one hour per day? 9 Yes 9 No
If Yes, describe possible sources, potential frequency and duration of odor emissions, and proximity to nearest
occupied structures: ______________________________________________________________________________________
p. Will the proposed action include any bulk storage of petroleum (combined capacity of over 1,100 gallons)9 Yes 9 No
or chemical products 185 gallons in above ground storage or any amount in underground storage?
If Yes:
i.Product(s) to be stored ______________________________________________________________________________________
ii.Volume(s) ______ per unit time ___________ (e.g., month, year)
iii.Generally, describe the proposed storage facilities:________________________________________________________________
q. Will the proposed action (commercial, industrial and recreational projects only) use pesticides (i.e., herbicides,9 Yes 9 No
insecticides) during construction or operation?
If Yes:
i.Describe proposed treatment(s):
ii.Will the proposed action use Integrated Pest Management Practices?9 Yes 9 No
r. Will the proposed action (commercial or industrial projects only) involve or require the management or disposal 9 Yes 9 No
of solid waste (excluding hazardous materials)?
If Yes:
i.Describe any solid waste(s) to be generated during construction or operation of the facility:
Construction: ____________________ tons per ________________ (unit of time)
Operation : ____________________ tons per ________________ (unit of time)
ii.Describe any proposals for on-site minimization, recycling or reuse of materials to avoid disposal as solid waste:
Construction: ________________________________________________________________________________________
Operation: __________________________________________________________________________________________
iii.Proposed disposal methods/facilities for solid waste generated on-site:
Construction: ________________________________________________________________________________________
Operation: __________________________________________________________________________________________
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N/A
Construction: Typical construction and jobsite activity noise: Diesel engines, dump trucks, excavators, etc.
Operations: PA system, spectators, field hockey activity during practices and games
Twenty-two 20' pedestrian lights will be installed in the proposed parking lot and along the sidewalk/path circulation areas between parking, field
hockey field, and support facility locations. Four 70' tall standard athletic lighting poles will be sited at the corners of the field hockey field.
If necessary, a professional will apply pesticides or herbicides to control unwanted vegetation and pests. Cornell utilizes an
Integrated Pest Management approach to grounds management on campus that will be used at this site as well.
Project is not a commercial or industrial project
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s. Does the proposed action include construction or modification of a solid waste management facility?9 Yes 9 No
If Yes:
i.Type of management or handling of waste proposed for the site (e.g., recycling or transfer station, composting, landfill, or
other disposal activities): ___________________________________________________________________________________
ii.Anticipated rate of disposal/processing:
Tons/month, if transfer or other non-combustion/thermal treatment, or
Tons/hour, if combustion or thermal treatment
iii.If landfill, anticipated site life: ________________________________ years
t. Will the proposed action at the site involve the commercial generation, treatment, storage, or disposal of hazardous 9 Yes 9 No
waste?
If Yes:
i.Name(s) of all hazardous wastes or constituents to be generated, handled or managed at facility: ___________________________
ii.Generally describe processes or activities involving hazardous wastes or constituents: ___________________________________
iii. Specify amount to be handled or generated _____ tons/month
iv.Describe any proposals for on-site minimization, recycling or reuse of hazardous constituents: ____________________________
v.Will any hazardous wastes be disposed at an existing offsite hazardous waste facility? 9 Yes 9 No
If Yes: provide name and location of facility: _______________________________________________________________________
If No: describe proposed management of any hazardous wastes which will not be sent to a hazardous waste facility:
E.Site and Setting of Proposed Action
E.1. Land uses on and surrounding the project site
a. Existing land uses.
i.Check all uses that occur on, adjoining and near the project site.
9 Urban 9 Industrial 9 Commercial 9 Residential (suburban) 9 Rural (non-farm)
9 Forest 9 Agriculture 9 Aquatic 9 Other (specify): ____________________________________
ii.If mix of uses, generally describe:
b. Land uses and covertypes on the project site.
Land use or
Covertype
Current
Acreage
Acreage After
Project Completion
Change
Acres +/-)
Roads, buildings, and other paved or impervious
surfaces
Forested
Meadows, grasslands or brushlands (non-
agricultural, including abandoned agricultural)
Agricultural
includes active orchards, field, greenhouse etc.)
Surface water features
lakes, ponds, streams, rivers, etc.)
Wetlands (freshwater or tidal)
Non-vegetated (bare rock, earth or fill)
Other
Describe: _______________________________
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soccer fields and baseball diamond
1.55 5.02 +3.47
4.70 2.53 -2.17
0.10 0.33 +0.23
Lawn 9.30 7.77 -1.53
Cascadilla Creek is located approx. 575+/- ft north of project)
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c. Is the project site presently used by members of the community for public recreation? 9 Yes 9 No
i.If Yes: explain: __________________________________________________________________________________________
d. Are there any facilities serving children, the elderly, people with disabilities (e.g., schools, hospitals, licensed 9 Yes 9 No
day care centers, or group homes) within 1500 feet of the project site?
If Yes,
i.Identify Facilities:
e. Does the project site contain an existing dam? 9 Yes 9 No
If Yes:
i.Dimensions of the dam and impoundment:
Dam height: _________________________________ feet
Dam length: _________________________________ feet
Surface area: _________________________________ acres
Volume impounded: _______________________________ gallons OR acre-feet
ii.Dam=s existing hazard classification: _________________________________________________________________________
iii.Provide date and summarize results of last inspection:
f. Has the project site ever been used as a municipal, commercial or industrial solid waste management facility, 9 Yes 9 No
or does the project site adjoin property which is now, or was at one time, used as a solid waste management facility?
If Yes:
i.Has the facility been formally closed? 9 Yes 9 No
If yes, cite sources/documentation: _______________________________________________________________________
ii.Describe the location of the project site relative to the boundaries of the solid waste management facility:
iii.Describe any development constraints due to the prior solid waste activities: __________________________________________
g. Have hazardous wastes been generated, treated and/or disposed of at the site, or does the project site adjoin 9 Yes 9 No
property which is now or was at one time used to commercially treat, store and/or dispose of hazardous waste?
If Yes:
i.Describe waste(s) handled and waste management activities, including approximate time when activities occurred:
h. Potential contamination history. Has there been a reported spill at the proposed project site, or have any 9 Yes 9 No
remedial actions been conducted at or adjacent to the proposed site?
If Yes:
i.Is any portion of the site listed on the NYSDEC Spills Incidents database or Environmental Site 9 Yes 9 No
Remediation database? Check all that apply:
9 Yes – Spills Incidents database Provide DEC ID number(s): ________________________________
9 Yes – Environmental Site Remediation database Provide DEC ID number(s): ________________________________
9 Neither database
ii.If site has been subject of RCRA corrective activities, describe control measures:_______________________________________
iii.Is the project within 2000 feet of any site in the NYSDEC Environmental Site Remediation database? 9 Yes 9 No
If yes, provide DEC ID number(s): ______________________________________________________________________________
iv.If yes to (i), (ii) or (iii) above, describe current status of site(s):
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v.Is the project site subject to an institutional control limiting property uses? 9 Yes 9 No
If yes, DEC site ID number: ____________________________________________________________________________
Describe the type of institutional control (e.g., deed restriction or easement): ____________________________________
Describe any use limitations: ___________________________________________________________________________
Describe any engineering controls: _______________________________________________________________________
Will the project affect the institutional or engineering controls in place? 9 Yes 9 No
Explain: ____________________________________________________________________________________________
E.2. Natural Resources On or Near Project Site
a. What is the average depth to bedrock on the project site? ________________ feet
b. Are there bedrock outcroppings on the project site? 9 Yes 9 No
If Yes, what proportion of the site is comprised of bedrock outcroppings? __________________%
c. Predominant soil type(s) present on project site: ___________________________ __________%
d. What is the average depth to the water table on the project site? Average: _________ feet
e. Drainage status of project site soils: 9 Well Drained: _____% of site
9 Moderately Well Drained: _____% of site
9 Poorly Drained _____% of site
f. Approximate proportion of proposed action site with slopes: 9 0-10%: _____% of site
9 10-15%: _____% of site
9 15% or greater: _____% of site
g. Are there any unique geologic features on the project site? 9 Yes 9 No
If Yes, describe: _____________________________________________________________________________________________
h. Surface water features.
i.Does any portion of the project site contain wetlands or other waterbodies (including streams, rivers, 9 Yes 9 No
ponds or lakes)?
ii.Do any wetlands or other waterbodies adjoin the project site? 9 Yes 9 No
If Yes to either i or ii, continue. If No, skip to E.2.i.
iii.Are any of the wetlands or waterbodies within or adjoining the project site regulated by any federal, 9 Yes 9 No
state or local agency?
iv.For each identified regulated wetland and waterbody on the project site, provide the following information:
Streams: Name ____________________________________________Classification _______________________•
Lakes or Ponds:Name ____________________________________________Classification _______________________•
Wetlands: Name ____________________________________________Approximate Size ___________________ •
Wetland No. (if regulated by DEC) _____________________________
v.Are any of the above water bodies listed in the most recent compilation of NYS water quality-impaired 9 Yes 9 No
waterbodies?
If yes, name of impaired water body/bodies and basis for listing as impaired: _____________________________________________
i.Is the project site in a designated Floodway? 9 Yes 9 No
j.Is the project site in the 100-year Floodplain? 9 Yes 9 No
k.Is the project site in the 500-year Floodplain? 9 Yes 9 No
l. Is the project site located over, or immediately adjoining, a primary, principal or sole source aquifer? 9 Yes 9 No
If Yes:
i.Name of aquifer: _________________________________________________________________________________________
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10
N/A
Silt mixed with clay and trace sand.100
Glacial Till (>13 ft depth)
10
100
100
RiverineCascadillaCreek
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m. Identify the predominant wildlife species that occupy or use the project site:
n. Does the project site contain a designated significant natural community? 9 Yes 9 No
If Yes:
i.Describe the habitat/community (composition, function, and basis for designation): _____________________________________
ii.Source(s) of description or evaluation: ________________________________________________________________________
iii.Extent of community/habitat:
Currently:______________________ acres
Following completion of project as proposed: _____________________ acres
Gain or loss (indicate + or -): ______________________ acres
o. Does project site contain any species of plant or animal that is listed by the federal government or NYS as 9 Yes 9 No
endangered or threatened, or does it contain any areas identified as habitat for an endangered or threatened species?
If Yes:
i.Species and listing (endangered or threatened):______________________________________________________________________________
p. Does the project site contain any species of plant or animal that is listed by NYS as rare, or as a species of 9 Yes 9 No
special concern?
If Yes:
i.Species and listing:____________________________________________________________________________________________________
q. Is the project site or adjoining area currently used for hunting, trapping, fishing or shell fishing? 9 Yes 9 No
If yes, give a brief description of how the proposed action may affect that use: ___________________________________________
E.3. Designated Public Resources On or Near Project Site
a. Is the project site, or any portion of it, located in a designated agricultural district certified pursuant to 9 Yes 9 No
Agriculture and Markets Law, Article 25-AA, Section 303 and 304?
If Yes, provide county plus district name/number: _________________________________________________________________
b. Are agricultural lands consisting of highly productive soils present? 9 Yes 9 No
i.If Yes: acreage(s) on project site? ___________________________________________________________________________
ii.Source(s) of soil rating(s): _________________________________________________________________________________
c. Does the project site contain all or part of, or is it substantially contiguous to, a registered National 9 Yes 9 No
Natural Landmark?
If Yes:
i.Nature of the natural landmark: 9 Biological Community 9 Geological Feature
ii.Provide brief description of landmark, including values behind designation and approximate size/extent: ___________________
d. Is the project site located in or does it adjoin a state listed Critical Environmental Area? 9 Yes 9 No
If Yes:
i.CEA name: _____________________________________________________________________________________________
ii.Basis for designation: _____________________________________________________________________________________
iii.Designating agency and date: ______________________________________________________________________________
Page 12 of 13
Deer Rodents Garter Snakes
Three Birds Orchid is identified on the EAF Mapper, but the conditions for this species do not exist on the project site.
NRCS Soil Mapping
Approx. 16 acres between 3 parcels, located south of the project. See Parts 2 & 3
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e. Does the project site contain, or is it substantially contiguous to, a building, archaeological site, or district 9 Yes 9 No
which is listed on the National or State Register of Historic Places, or that has been determined by the Commissioner of the NYS
Office of Parks, Recreation and Historic Preservation to be eligible for listing on the State Register of Historic Places?
If Yes:
i.Nature of historic/archaeological resource: 9 Archaeological Site 9 Historic Building or District
ii.Name: _________________________________________________________________________________________________
iii.Brief description of attributes on which listing is based:
f. Is the project site, or any portion of it, located in or adjacent to an area designated as sensitive for 9 Yes 9 No
archaeological sites on the NY State Historic Preservation Office (SHPO) archaeological site inventory?
g. Have additional archaeological or historic site(s) or resources been identified on the project site? 9 Yes 9 No
If Yes:
i. Describe possible resource(s): _______________________________________________________________________________
ii.Basis for identification: ___________________________________________________________________________________
h.Is the project site within fives miles of any officially designated and publicly accessible federal, state, or local 9 Yes 9 No
scenic or aesthetic resource?
If Yes:
i.Identify resource: _________________________________________________________________________________________
ii.Nature of, or basis for, designation (e.g., established highway overlook, state or local park, state historic trail or scenic byway,
etc.): ___________________________________________________________________________________________________
iii.Distance between project and resource: _____________________ miles.
i. Is the project site located within a designated river corridor under the Wild, Scenic and Recreational Rivers 9 Yes 9 No
Program 6 NYCRR 666?
If Yes:
i.Identify the name of the river and its designation: ________________________________________________________________
ii.Is the activity consistent with development restrictions contained in 6NYCRR Part 666? 9 Yes 9 No
F.Additional Information
Attach any additional information which may be needed to clarify your project.
If you have identified any adverse impacts which could be associated with your proposal, please describe those impacts plus any
measures which you propose to avoid or minimize them.
G. Verification
I certify that the information provided is true to the best of my knowledge.
Applicant/Sponsor Name ___________________________________ Date_______________________________________
Signature________________________________________________ Title_______________________________________
Page 13 of 13
Eligible property: CCC Camp SP-48 (140 Game Farm Road)
Former Civilian Conservation Corp building (shed) located on the property
Former CCC building (see above), 19th century farm sites, Native American sites
Multiple archaeology investigations.
Cayuga Lake Byway; Town-Designated View on Pine Tree Road; County-Designated View on Turkey Hill/Dodge Road
Scenic byway, designated views
Byway +/-2.7; Views +/- 0.5
Kimberly Michaels October 1, 2024
PRINT FORM
Director of Landscape Architecture
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Impact on Land
The proposed development is located adjacent to McGovern Soccer Fields on Game Farm Road, and two overhead NYSEG
transmission lines. The project area currently consists of a previously developed grass soccer field and a drive lane that connects
Game Farm Road to McGovern Fields. Land disturbance for the project will be limited to excavation for utilities (septic, water
service, drainage, electrical), field development, support facility development, site earthwork, and pavement installation. All
excavated material is intended to be used on site. Existing drainage patterns will be emulated to the extent possible. Erosion
and sediment controls will be implemented during construction as outlined in the project SWPPP, and the site will ultimately be
stabilized with vegetation. No significant adverse impacts to land are anticipated.
Impact on Water
The site currently drains to Cascadilla Creek, which lies north of the project site, and runs to the west, ultimately to Cayuga
Lake. The watershed contributing to Cascadilla Creek is greater than 1,500 acres. The proposed development conforms to the
Town of Ithaca Stream Setback Law and is greater than 100 feet from the southern stream bank. Based on a review of the FEMA
Flood Insurance Rate Map for the Town of Ithaca, NY (dated June 19, 1985), the project property is located in flood zone “C” for
Cascadilla Creek. The FEMA definition of flood zone “C” is areas that are of minimal flood hazard, and higher than the elevation
of the 0.2-percent-annual-chance-flood.
There are neither federal nor state wetlands located on the project site. The National Wetlands Inventory indicates that the
adjacent Cascadilla Creek area is a Forested/Shrub Wetland, but the project will not disturb land within that area.
The stormwater management design will reduce runoff discharge from the project area for the 1, 10, and 100-year storm events,
and will provide Water Quality Treatment, Runoff Reduction, and Erosion Control Measures to meet the NYSDEC and Town of
Ithaca requirements.
Potable water for domestic, fire protection, and Field Hockey watering purposes will be supplied from the Cornell University Zone
3 distribution grid. This system has adequate capacity to accommodate the project. The distribution main will be protected from
the Field Hockey watering system with an approved backflow prevention assembly.
Wastewater collected from the proposed buildings will be directed to an on-site septic tank.
No significant adverse impacts to water are anticipated as a result of the project.
Impact on Air
The proposed project will include no new emissions sources and therefore is expected to have no adverse impacts on air quality.
Impact on Plants, Animals, & Agriculture
The existing project site consists of a previously developed grass soccer field and a gravel drive lane; is adjacent to two other
improved soccer fields; and is currently characterized by mowed grass, surrounded by fallow fields. One pine tree (4” DBH) will
be removed as part of the construction of this project. This land has not been used in the last 20 years for agriculture and is not
within an Agricultural or Farmland Protection Zone.
According to the NYSDEC Environmental Resource Mapper which provides generalized locations of Rare Plants and Animals,
the Three Birds Orchid is identified as potentially inhabiting these parcels. The Three Birds Orchid habitat is beech forest, which
does not exist on the project site. No significant adverse impacts to plants, animals, or agriculture are expected as a result of this
project.
Impact on Aesthetic Resources
The proposed project is not located within an identified viewshed and will be surrounded by similar athletic facilities, therefore
no significant adverse impacts to aesthetic resources are expected.
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Impact on Historic, Cultural, and Archaeological Resources
According to SHPO CRIS, the entire project parcel is within an “archaeological buffer area”. Between 2003 to 2021, Public
Archaeology Facility (PAF) and Panamerican archaeologists surveyed and investigated roughly 43% of the current and former
agricultural fields owned by Cornell University along Game Farm Road, Ellis Hollow Road, and Pine Tree Road. From these
investigations, four precontact Indigenous sites, one historic site, and one precontact site with an associated early historic
component were identified within the properties owned by Cornell University. Most of these site areas were either investigated at
the Phase 2 level of analysis and found to be not eligible for the National Register as individual sites or were not recommended
as potentially eligible after the Phase 1 surveys. Of the precontact sites, only one produced the cultural material results
consistent with a high research potential, and through consultation with NYS OPRHP an Alternative Mitigation Report was
developed to summarize, analyze, and interpret all of the Cascadilla Creek Sites within an archaeological district focused on
upland sites in marginal environmental settings. The studies have identified one area of potential archaeologic interest, and that
area is not within the project site. For more information, refer to the Phase I Reconnaissance Addendum Survey (2024) appendix.
There are no structures, sites, or districts within the project properties that are currently listed on the State or National Register of
Historic Places. A shed located on the 62.-2-6 tax parcel (located north of the NYSEG transmission lines from the project site is
listed as an “Eligible” facility, as a Civilian Conservation Corps structure CCC Camps SP-48 at 140 Game Farm Road), according
to the New York State Historic Preservation Office (SHPO) Cultural Resources Information System (CRIS). This structure will not
be impacted by the proposed project.
The project team is coordinating with SHPO and expects to receive a letter of concurrence with PAF’s findings in November. This
letter will be provided to planning staff once available.
Impact on Open Space & Recreation
The project site consists of a previously developed grass soccer field and a driveway with informal parking that is accessed from
Game Farm Road. The project site is adjacent to McGovern soccer fields and a small fieldhouse used by Cornell Athletics. The
new Field Hockey venue will be consistent with these active recreation land uses. The project site will not impact the East Ithaca
Recreation Way trail, a nearby open space amenity. The project will have a positive impact on university recreational space by
providing Cornell University’s field hockey athletes with a new playing field. No negative impacts to open space or recreation are
anticipated as a result of the proposed project.
Impact on Critical Environmental and Unique Natural Areas
There are no designated critical environmental areas (CEA) within or immediately adjacent to the proposed project. The nearest
CEA, Coy Glen, is located approximately four miles west of the project site.
The Cascadilla Creek Woods and Fish Ponds Unique Natural Area is located north of the project site. As previously noted, all site
development is at least over 100 feet from the creek, compliant with the Town of Ithaca’s Stream Setback Law. Site grading and
other proposed improvements are outside of the UNA boundary. Stormwater management features are being designed for the
project to protect downstream features. No adverse impact to Unique Natural Areas is anticipated as a result of the project.
Impact on Transportation
Parking Impacts
The project will provide 120 paved parking spaces to support both the proposed field hockey venue and existing soccer practice
fields. This will provide adequate parking, based on detailed projected use for these functions. The project is not anticipated to
result in adverse impacts to parking.
Traffic Impacts
The complex lies on the west side of Game Farm Road, a Tompkins County road where the street centerline is identified as the
municipal boundary between the Town of Ithaca and the Town of Dryden. The soccer and proposed field hockey facilities are
accessed directly and solely via Game Farm Road, which runs for just over one mile between NYS Route 366 to the north and
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Tompkins County’s Ellis Hollow Road to the south.
Field hockey practices are anticipated to generate up to 18 vehicle trips between 6:30-9:00AM Mon-Friday. Field Hockey
competitions are anticipated to generate up to 74 car roundtrips and one or two buses in the afternoon/evening hours. These
additional vehicle trips are not expected to impact the level of service on Game Farm Road or to disrupt typical traffic patterns.
Please see Traffic and Parking study memo appendix for more information.
The project is not anticipated to result in adverse impacts to local traffic or parking.
Impact on Energy
The project is not anticipated to result in adverse impacts to energy. The project facilities and lighting will be supplied by the
existing NYSEG electric service along Game Farm Road. Service is presently extended to the McGovern field soccer facility.
The field hockey facilities are small and require relatively low energy loads, and the electrical capacity is sufficient to supply the
programmatic needs of the project. No propane or other natural gas is proposed for this project. The project will comply with the
Ithaca Energy Code Supplement.
Impacts from Sound, Odor & Light
Sound generation will be restricted to typical noise associated with athletic facilities, including a sound system for warm up
music, and expected competition sound including spectator cheering and commentating. The sound system is designed to
project sound from east to west across the field to reach spectators within the field area, the dugouts, and the press box, while
minimizing the volume of noise to the surrounding area.
A sound study has been completed for the proposed project and is provided as an appendix. By focusing sound west, toward the
field hockey field, volume is greatly mitigated for the surrounding areas, including residences located to the south of the project
site along Game Farm Road. Modeling for the audio system indicates that the project will not increase noise over existing sound
levels.
There are no significant odor-producing aspects from the field and associated operations.
Four, 70’ tall athletics field light poles will flank the field hockey field to provide sufficient, safe lighting to support both
competition and practice play. Pedestrian lighting will be Cornell standard LED fixtures that are energy efficient and dark-sky
compliant. No light trespass will occur.
No significant adverse impacts to sound, odor or light are anticipated as a result of the project.
Impact on Human Health
This project proposes to build one NCAA-compliant synthetic turf field hockey field to support a needed practice and
competition venue for the varsity field hockey team. Much scrutiny and research has been completed to specify this field
to ensure that Cornell athletes, visitors to the field, and the general public health are protected. Synthetic turf, as proposed
for this project, has been shown to pose no health risk in more than 110 technical studies conducted by a variety of trusted
scientific authorities, including the US EPA, US Department of Energy and Environment, Washington State Department of
Health, and more. The proposed synthetic turf installed at Game Farm Road will meet the requirements set forth in New York
State Environmental Conservation Law, Section 27-3313(2). (“On and after December thirty-first, two thousand twenty-six, no
carpet sold or offered for sale in the state shall contain or be treated with PFAS substances for any purpose.”). Additionally, the
synthetic turf will not include infill.
From an air quality perspective, health agencies in New York State, New York City, and the State of Connecticut collected air
samples on synthetic and natural turf fields during use. The air samples were analyzed for volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), and airborne particulate matter. The studies showed that inhalation exposures
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resulting from playing on synthetic turf fields were insignificant and not different from inhalation exposures on natural grass
fields.
Impact on Growth & Character of Community
The field hockey field will expand athletics activities on Cornell’s Game Farm Road lands, while retaining a sense of openness,
rural character and vernacular in its field and facility development. The update from a lightly used grass soccer field to a regularly
used field hockey facility will not significantly change the area. There are no significant adverse impacts to the character of the
community anticipated as a result of the project.
Impacts from Construction
Construction for phase I is anticipated to take approximately six months, beginning in March 2025 with completion in August
2025.
Construction may have short-term impacts to the community as the development period is brief. Construction routes will utilize
approved truck routes and Tompkins County roads to Ellis Hollow and Game Farm Road. The project will have erosion control
features outlined in the SWPPP and as previously described, to protect the public and the environment. Construction will be
limited to 7am to 3pm to minimize afternoon and evening disturbances.
Staging and laydown will be located on a Cornell lot located just north of the proposed Field Hockey Field and Northeast of the
existing McGovern Fields on a disturbed parking area previously used for other project staging.
Temporary traffic controls will be provided on Game Farm Road only as needed but are not anticipated frequently. Emergency
vehicles will have access to the site for the duration of construction. Waste from construction will be disposed of legally and
appropriately.
Construction vehicles will be directed to access the site via a prescribed route either north or south from Game Farm Road for
field development. The project will generate approximately 300 truck roundtrips over a two-month period. The largest volumes
of truck activity would be associated with importing general fill used for rough grading the site and bringing the new field up to
finished grade elevation, when a maximum of 30 trucks could be expected to arrive on site in a single day.
Most long-distance delivery routes to/from Cornell’s campus utilize route 81 north or south. Traffic leaving the site and heading
north would utilize NYS Route 366 to NYS Routes 13 to 81 north. Traffic leaving the site and heading south would use Tompkins
County Roads: Ellis Hollow Road to Pine Tree Road (an approved truck route), on to NYS Routes 79 to 81 south.
Due to the project location and the fact that appropriate safety controls and best work practices will be followed, there should be
negligible adverse impacts from construction.
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Figure: Site Logistics - March 2025 through August 2025
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Page 1 of 10
Full Environmental Assessment Form
Part 2 - Identification of Potential Project Impacts
Part 2 is to be completed by the lead agency. Part 2 is designed to help the lead agency inventory all potential resources that could
be affected by a proposed project or action. We recognize that the lead agency=s reviewer(s) will not necessarily be environmental
professionals. So, the questions are designed to walk a reviewer through the assessment process by providing a series of questions that
can be answered using the information found in Part 1. To further assist the lead agency in completing Part 2, the form identifies the
most relevant questions in Part 1 that will provide the information needed to answer the Part 2 question. When Part 2 is completed, the
lead agency will have identified the relevant environmental areas that may be impacted by the proposed activity.
If the lead agency is a state agency and the action is in any Coastal Area, complete the Coastal Assessment Form before proceeding
with this assessment.
Tips for completing Part 2:
Review all of the information provided in Part 1.
Review any application, maps, supporting materials and the Full EAF Workbook.
Answer each of the 18 questions in Part 2.
If you answer “Yes” to a numbered question, please complete all the questions that follow in that section.
If you answer “No” to a numbered question, move on to the next numbered question.
Check appropriate column to indicate the anticipated size of the impact.
Proposed projects that would exceed a numeric threshold contained in a question should result in the reviewing agency
checking the box “Moderate to large impact may occur.”
The reviewer is not expected to be an expert in environmental analysis.
If you are not sure or undecided about the size of an impact, it may help to review the sub-questions for the general
question and consult the workbook.
When answering a question consider all components of the proposed activity, that is, the Awhole action@.
Consider the possibility for long-term and cumulative impacts as well as direct impacts.
Answer the question in a reasonable manner considering the scale and context of the project.
1.Impact on Land
Proposed action may involve construction on, or physical alteration of,NO YES
the land surface of the proposed site. (See Part 1. D.1)
If “Yes”, answer questions a - j. If “No”, move on to Section 2.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may involve construction on land where depth to water table is
less than 3 feet.
E2d 9 9
b. The proposed action may involve construction on slopes of 15% or greater.E2f 9 9
c. The proposed action may involve construction on land where bedrock is exposed, or
generally within 5 feet of existing ground surface.
E2a 9 9
d. The proposed action may involve the excavation and removal of more than 1,000 tons
of natural material.
D2a 9 9
e. The proposed action may involve construction that continues for more than one year
or in multiple phases.
D1e 9 9
f. The proposed action may result in increased erosion, whether from physical
disturbance or vegetation removal (including from treatment by herbicides).
D2e, D2q 9 9
g. The proposed action is, or may be, located within a Coastal Erosion hazard area.B1i 9 9
h. Other impacts: _______________________________________________________9 9
Agency Use Only [If applicable]
Project :
Date :
FEAF 2019
Highlighted sections are elaborated in
Part 3 attachment
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Page 2 of 10
2.Impact on Geological Features
The proposed action may result in the modification or destruction of, or inhibit
access to, any unique or unusual land forms on the site (e.g., cliffs, dunes, NO YES
minerals, fossils, caves). (See Part 1. E.2.g)
If “Yes”, answer questions a - c. If “No”, move on to Section 3.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. Identify the specific land form(s) attached: ________________________________E2g 9 9
b. The proposed action may affect or is adjacent to a geological feature listed as a
registered National Natural Landmark.
Specific feature: _____________________________________________________
E3c 9 9
c.Other impacts: ______________________________________________________9 9
3.Impacts on Surface Water
The proposed action may affect one or more wetlands or other surface water NO YES
bodies (e.g., streams, rivers, ponds or lakes). (See Part 1. D.2, E.2.h)
If “Yes”, answer questions a - l. If “No”, move on to Section 4.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may create a new water body.D2b, D1h 9 9
b. The proposed action may result in an increase or decrease of over 10% or more than a
10 acre increase or decrease in the surface area of any body of water.
D2b 9 9
c. The proposed action may involve dredging more than 100 cubic yards of material
from a wetland or water body.
D2a 9 9
d. The proposed action may involve construction within or adjoining a freshwater or
tidal wetland, or in the bed or banks of any other water body.
E2h 9 9
e. The proposed action may create turbidity in a waterbody, either from upland erosion,
runoff or by disturbing bottom sediments.
D2a, D2h 9 9
f.The proposed action may include construction of one or more intake(s) for withdrawal
of water from surface water.
D2c 9 9
g.The proposed action may include construction of one or more outfall(s) for discharge
of wastewater to surface water(s).
D2d 9 9
h.The proposed action may cause soil erosion, or otherwise create a source of
stormwater discharge that may lead to siltation or other degradation of receiving
water bodies.
D2e 9 9
i. The proposed action may affect the water quality of any water bodies within or
downstream of the site of the proposed action.
E2h 9 9
j. The proposed action may involve the application of pesticides or herbicides in or
around any water body.
D2q, E2h 9 9
k. The proposed action may require the construction of new, or expansion of existing,
wastewater treatment facilities.
D1a, D2d 9 9
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l. Other impacts: _______________________________________________________9 9
4.Impact on groundwater
The proposed action may result in new or additional use of ground water, or NO YES
may have the potential to introduce contaminants to ground water or an aquifer.
See Part 1. D.2.a, D.2.c, D.2.d, D.2.p, D.2.q, D.2.t)
If “Yes”, answer questions a - h. If “No”, move on to Section 5.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may require new water supply wells, or create additional demand
on supplies from existing water supply wells.
D2c 9 9
b. Water supply demand from the proposed action may exceed safe and sustainable
withdrawal capacity rate of the local supply or aquifer.
Cite Source: ________________________________________________________
D2c 9 9
c. The proposed action may allow or result in residential uses in areas without water and
sewer services.
D1a, D2c 9 9
d. The proposed action may include or require wastewater discharged to groundwater.D2d, E2l 9 9
e. The proposed action may result in the construction of water supply wells in locations
where groundwater is, or is suspected to be, contaminated.
D2c, E1f,
E1g, E1h
9 9
f. The proposed action may require the bulk storage of petroleum or chemical products
over ground water or an aquifer.
D2p, E2l 9 9
g. The proposed action may involve the commercial application of pesticides within 100
feet of potable drinking water or irrigation sources.
E2h, D2q,
E2l, D2c
9 9
h. Other impacts: ______________________________________________________9 9
5.Impact on Flooding
The proposed action may result in development on lands subject to flooding.NO YES
See Part 1. E.2)
If “Yes”, answer questions a - g. If “No”, move on to Section 6.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may result in development in a designated floodway.E2i 9 9
b. The proposed action may result in development within a 100 year floodplain.E2j 9 9
c. The proposed action may result in development within a 500 year floodplain.E2k 9 9
d. The proposed action may result in, or require, modification of existing drainage
patterns.
D2b, D2e 9 9
e. The proposed action may change flood water flows that contribute to flooding.D2b, E2i,
E2j, E2k
9 9
f.If there is a dam located on the site of the proposed action, is the dam in need of repair,
or upgrade?
E1e 9 9
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g. Other impacts: ______________________________________________________9 9
6.Impacts on Air
NO YESTheproposedactionmayincludeastateregulatedairemissionsource.
See Part 1. D.2.f., D.2.h, D.2.g)
If “Yes”, answer questions a - f. If “No”, move on to Section 7.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. If the proposed action requires federal or state air emission permits, the action may
also emit one or more greenhouse gases at or above the following levels:
i. More than 1000 tons/year of carbon dioxide (CO2)
ii.More than 3.5 tons/year of nitrous oxide (N2O)
iii. More than 1000 tons/year of carbon equivalent of perfluorocarbons (PFCs)
iv. More than .045 tons/year of sulfur hexafluoride (SF6)
v. More than 1000 tons/year of carbon dioxide equivalent of
hydrochloroflourocarbons (HFCs) emissions
vi. 43 tons/year or more of methane
D2g
D2g
D2g
D2g
D2g
D2h
9
9
9
9
9
9
9
9
9
9
9
9
b. The proposed action may generate 10 tons/year or more of any one designated
hazardous air pollutant, or 25 tons/year or more of any combination of such hazardous
air pollutants.
D2g 9 9
c. The proposed action may require a state air registration, or may produce an emissions
rate of total contaminants that may exceed 5 lbs. per hour, or may include a heat
source capable of producing more than 10 million BTU=s per hour.
D2f, D2g 9 9
d.The proposed action may reach 50% of any of the thresholds in “a” through “c”,
above.
D2g 9 9
e. The proposed action may result in the combustion or thermal treatment of more than 1
ton of refuse per hour.
D2s 9 9
9
7.Impact on Plants and Animals
The proposed action may result in a loss of flora or fauna. (See Part 1. E.2. m.-q.)NO YES
If “Yes”, answer questions a - j. If “No”, move on to Section 8.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a.The proposed action may cause reduction in population or loss of individuals of any
threatened or endangered species, as listed by New York State or the Federal
government, that use the site, or are found on, over, or near the site.
E2o 9 9
b. The proposed action may result in a reduction or degradation of any habitat used by
any rare, threatened or endangered species, as listed by New York State or the federal
government.
E2o 9 9
c. The proposed action may cause reduction in population, or loss of individuals, of any
species of special concern or conservation need, as listed by New York State or the
Federal government, that use the site, or are found on, over, or near the site.
E2p 9 9
d. The proposed action may result in a reduction or degradation of any habitat used by
any species of special concern and conservation need, as listed by New York State or
the Federal government.
E2p 9 9
f. Other impacts: ___ _ _ _ ___ __ ___ _ ___ _ _ _ _ ____ _ _ _ _ __ _ _ _ _ _ _ __ ___ ___ __ _ __ _ _ _9
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Page 5 of 10
e. The proposed action may diminish the capacity of a registered National Natural
Landmark to support the biological community it was established to protect.
E3c 9 9
f. The proposed action may result in the removal of, or ground disturbance in, any
portion of a designated significant natural community.
Source: ____________________________________________________________
E2n 9 9
g. The proposed action may substantially interfere with nesting/breeding, foraging, or
over-wintering habitat for the predominant species that occupy or use the project site.E2m 9 9
h. The proposed action requires the conversion of more than 10 acres of forest,
grassland or any other regionally or locally important habitat.
Habitat type & information source: ______________________________________
E1b 9 9
i. Proposed action (commercial, industrial or recreational projects, only) involves use of
herbicides or pesticides.
D2q 9 9
j. Other impacts: ______________________________________________________9 9
8.Impact on Agricultural Resources
The proposed action may impact agricultural resources. (See Part 1. E.3.a. and b.)NO YES
If “Yes”, answer questions a - h. If “No”, move on to Section 9.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may impact soil classified within soil group 1 through 4 of the
NYS Land Classification System.
E2c, E3b 9 9
b. The proposed action may sever, cross or otherwise limit access to agricultural land
includes cropland, hayfields, pasture, vineyard, orchard, etc).
E1a, Elb 9 9
c. The proposed action may result in the excavation or compaction of the soil profile of
active agricultural land.
E3b 9 9
d. The proposed action may irreversibly convert agricultural land to non-agricultural
uses, either more than 2.5 acres if located in an Agricultural District, or more than 10
acres if not within an Agricultural District.
E1b, E3a 9 9
e. The proposed action may disrupt or prevent installation of an agricultural land
management system.
El a, E1b 9 9
f. The proposed action may result, directly or indirectly, in increased development
potential or pressure on farmland.
C2c, C3,
D2c, D2d
9 9
g. The proposed project is not consistent with the adopted municipal Farmland
Protection Plan.
C2c 9 9
99h. Other impacts: ____________________________
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9. Impact on Aesthetic Resources
The land use of the proposed action are obviously different from, or are in NO YES
sharp contrast to, current land use patterns between the proposed project and
a scenic or aesthetic resource. (Part 1. E.1.a, E.1.b, E.3.h.)
If “Yes”, answer questions a - g. If “No”, go to Section 10.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. Proposed action may be visible from any officially designated federal, state, or local
scenic or aesthetic resource.
E3h 9 9
b. The proposed action may result in the obstruction, elimination or significant
screening of one or more officially designated scenic views.
E3h, C2b 9 9
c. The proposed action may be visible from publicly accessible vantage points:
i. Seasonally (e.g., screened by summer foliage, but visible during other seasons)
ii. Year round
E3h
9
9
9
9
d. The situation or activity in which viewers are engaged while viewing the proposed
action is:
i. Routine travel by residents, including travel to and from work
ii. Recreational or tourism based activities
E3h
E2q,
E1c 9
9
9
9
e. The proposed action may cause a diminishment of the public enjoyment and
appreciation of the designated aesthetic resource.
E3h 9 9
f. There are similar projects visible within the following distance of the proposed
project:
0-1/2 mile
3 mile
3-5 mile
5+ mile
D1a, E1a,
D1f, D1g
9 9
g.Other impacts: ______________________________________________________9 9
10. Impact on Historic and Archeological Resources
The proposed action may occur in or adjacent to a historic or archaeological NO YES
resource. (Part 1. E.3.e, f. and g.)
If “Yes”, answer questions a - e. If “No”, go to Section 11.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
E3e 9 9
b. The proposed action may occur wholly or partially within, or substantially contiguous
to, an area designated as sensitive for archaeological sites on the NY State Historic
Preservation Office (SHPO) archaeological site inventory.
E3f 9 9
c. The proposed action may occur wholly or partially within, or substantially contiguous
to, an archaeological site not included on the NY SHPO inventory.
Source: ____________________________________________________________
E3g 9 9
a.The proposed action may occur wholly or partially within, or substantially contiguous
to, any buildings, archaeological site or district which is listed on the National or
State Register of Historical Places, or that has been determined by the Commissioner
of the NYS Office of Parks, Recreation and Historic Preservation to be eligible for
listing on the State Register of Historic Places.
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d. Other impacts: ______________________________________________________9 9
e.
If any of the above (a-d) are answered “Moderate to large impact may
occur”, continue with the following questions to help support conclusions in Part 3:
i.The proposed action may result in the destruction or alteration of all or part
of the site or property.
ii.The proposed action may result in the alteration of the property’s setting or
integrity.
iii.The proposed action may result in the introduction of visual elements which
are out of character with the site or property, or may alter its setting.
E3e, E3g,
E3f
E3e, E3f,
E3g, E1a,
E1b
E3e, E3f,
E3g, E3h,
C2, C3
9
9
9
9
9
9
11. Impact on Open Space and Recreation
The proposed action may result in a loss of recreational opportunities or a NO YES
reduction of an open space resource as designated in any adopted
municipal open space plan.
See Part 1. C.2.c, E.1.c., E.2.q.)
If “Yes”, answer questions a - e. If “No”, go to Section 12.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may result in an impairment of natural functions, or “ecosystem
services”, provided by an undeveloped area, including but not limited to stormwater
storage, nutrient cycling, wildlife habitat.
D2e, E1b
E2h,
E2m, E2o,
E2n, E2p
9 9
b. The proposed action may result in the loss of a current or future recreational resource.C2a, E1c,
C2c, E2q
9 9
c. The proposed action may eliminate open space or recreational resource in an area
with few such resources.
C2a, C2c
E1c, E2q
9 9
d. The proposed action may result in loss of an area now used informally by the
community as an open space resource.
C2c, E1c 9 9
e. Other impacts: _____________________________________________________9 9
12. Impact on Critical Environmental Areas
The proposed action may be located within or adjacent to a critical NO YES
environmental area (CEA). (See Part 1. E.3.d)
If “Yes”, answer questions a - c. If “No”, go to Section 13.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may result in a reduction in the quantity of the resource or
characteristic which was the basis for designation of the CEA.
E3d 9 9
b. The proposed action may result in a reduction in the quality of the resource or
characteristic which was the basis for designation of the CEA.
E3d 9 9
c. Other impacts: ______________________________________________________9 9
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13. Impact on Transportation
The proposed action may result in a change to existing transportation systems.NO YES
See Part 1. D.2.j)
If “Yes”, answer questions a - f. If “No”, go to Section 14.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. Projected traffic increase may exceed capacity of existing road network.D2j 9 9
b. The proposed action may result in the construction of paved parking area for 500 or
more vehicles.
D2j 9 9
c. The proposed action will degrade existing transit access.D2j 9 9
d. The proposed action will degrade existing pedestrian or bicycle accommodations.D2j 9 9
e.The proposed action may alter the present pattern of movement of people or goods.D2j 9 9
f.Other impacts: ______________________________________________________9 9
14. Impact on Energy
The proposed action may cause an increase in the use of any form of energy.NO YES
See Part 1. D.2.k)
If “Yes”, answer questions a - e. If “No”, go to Section 15.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action will require a new, or an upgrade to an existing, substation.D2k 9 9
b. The proposed action will require the creation or extension of an energy transmission
or supply system to serve more than 50 single or two-family residences or to serve a
commercial or industrial use.
D1f,
D1q, D2k
9 9
c. The proposed action may utilize more than 2,500 MWhrs per year of electricity.D2k 9 9
d. The proposed action may involve heating and/or cooling of more than 100,000 square
feet of building area when completed.
D1g 9 9
e. Other Impacts: ________________________________________________________
15. Impact on Noise, Odor, and Light
The proposed action may result in an increase in noise, odors, or outdoor lighting. NO YES
See Part 1. D.2.m., n., and o.)
If “Yes”, answer questions a - f. If “No”, go to Section 16.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may produce sound above noise levels established by local
regulation.
D2m 9 9
b. The proposed action may result in blasting within 1,500 feet of any residence,
hospital, school, licensed day care center, or nursing home.
D2m, E1d 9 9
c. The proposed action may result in routine odors for more than one hour per day.D2o 9 9
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Page 9 of 10
d. The proposed action may result in light shining onto adjoining properties.D2n 9 9
e. The proposed action may result in lighting creating sky-glow brighter than existing
area conditions.
D2n, E1a 9 9
f. Other impacts: ______________________________________________________9 9
16. Impact on Human Health
The proposed action may have an impact on human health from exposure NO YES
to new or existing sources of contaminants. (See Part 1.D.2.q., E.1. d. f. g. and h.)
If “Yes”, answer questions a - m. If “No”, go to Section 17.
Relevant
Part I
Question(s)
No,or
small
impact
may cccur
Moderate
to large
impact may
occur
a. The proposed action is located within 1500 feet of a school, hospital, licensed day
care center, group home, nursing home or retirement community.
E1d 9 9
b. The site of the proposed action is currently undergoing remediation.E1g, E1h 9 9
c. There is a completed emergency spill remediation, or a completed environmental site
remediation on, or adjacent to, the site of the proposed action.
E1g, E1h 9 9
d.The site of the action is subject to an institutional control limiting the use of the
property (e.g., easement or deed restriction).
E1g, E1h 9 9
e. The proposed action may affect institutional control measures that were put in place
to ensure that the site remains protective of the environment and human health.
E1g, E1h 9 9
f. The proposed action has adequate control measures in place to ensure that future
generation, treatment and/or disposal of hazardous wastes will be protective of the
environment and human health.
D2t 9 9
g. The proposed action involves construction or modification of a solid waste
management facility.
D2q, E1f 9 9
h. The proposed action may result in the unearthing of solid or hazardous waste.D2q, E1f 9 9
i. The proposed action may result in an increase in the rate of disposal, or processing, of
solid waste.
D2r, D2s 9 9
j. The proposed action may result in excavation or other disturbance within 2000 feet of
a site used for the disposal of solid or hazardous waste.
E1f, E1g
E1h
9 9
k. The proposed action may result in the migration of explosive gases from a landfill
site to adjacent off site structures.
E1f, E1g 9 9
l. The proposed action may result in the release of contaminated leachate from the
project site.
D2s, E1f,
D2r
9 9
m. Other impacts: ______________________________________________________
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17. Consistency with Community Plans
The proposed action is not consistent with adopted land use plans. NO YES
See Part 1. C.1, C.2. and C.3.)
If “Yes”, answer questions a - h. If “No”, go to Section 18.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action’s land use components may be different from, or in sharp
contrast to, current surrounding land use pattern(s).
C2, C3, D1a
E1a, E1b
9 9
b. The proposed action will cause the permanent population of the city, town or village
in which the project is located to grow by more than 5%.
C2 9 9
c. The proposed action is inconsistent with local land use plans or zoning regulations. C2, C2, C3 9 9
d. The proposed action is inconsistent with any County plans, or other regional land use
plans.
C2, C2 9 9
e. The proposed action may cause a change in the density of development that is not
supported by existing infrastructure or is distant from existing infrastructure.
C3, D1c,
D1d, D1f,
D1d, Elb
9 9
f. The proposed action is located in an area characterized by low density development
that will require new or expanded public infrastructure.
C4, D2c, D2d
D2j
9 9
g. The proposed action may induce secondary development impacts (e.g., residential or
commercial development not included in the proposed action)
C2a 9 9
h. Other: _____________________________________________________________ 9 9
18. Consistency with Community Character
The proposed project is inconsistent with the existing community character. NO YES
See Part 1. C.2, C.3, D.2, E.3)
If “Yes”, answer questions a - g. If “No”, proceed to Part 3.
Relevant
Part I
Question(s)
No, or
small
impact
may occur
Moderate
to large
impact may
occur
a. The proposed action may replace or eliminate existing facilities, structures, or areas
of historic importance to the community.
E3e, E3f, E3g 9 9
b. The proposed action may create a demand for additional community services (e.g.
schools, police and fire)
C4 9 9
c. The proposed action may displace affordable or low-income housing in an area where
there is a shortage of such housing.
C2, C3, D1f
D1g, E1a
9 9
d. The proposed action may interfere with the use or enjoyment of officially recognized
or designated public resources.
C2, E3 9 9
e. The proposed action is inconsistent with the predominant architectural scale and
character.
C2, C3 9 9
f. Proposed action is inconsistent with the character of the existing natural landscape. C2, C3
E1a, E1b
E2g, E2h
9 9
g. Other impacts: ______________________________________________________ 9 9
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Full Environmental Assessment Form
Part 3 - Evaluation of the Magnitude and Importance of Project Impacts
and
Determination of Significance
Part 3 provides the reasons in support of the determination of significance. The lead agency must complete Part 3 for every question
in Part 2 where the impact has been identified as potentially moderate to large or where there is a need to explain why a particular
element of the proposed action will not, or may, result in a significant adverse environmental impact.
Based on the analysis in Part 3, the lead agency must decide whether to require an environmental impact statement to further assess
the proposed action or whether available information is sufficient for the lead agency to conclude that the proposed action will not
have a significant adverse environmental impact. By completing the certification on the next page, the lead agency can complete its
determination of significance.
Reasons Supporting This Determination:
To complete this section:
Identify the impact based on the Part 2 responses and describe its magnitude. Magnitude considers factors such as severity,
size or extent of an impact.
Assess the importance of the impact. Importance relates to the geographic scope, duration, probability of the impact
occurring, number of people affected by the impact and any additional environmental consequences if the impact were to
occur.
The assessment should take into consideration any design element or project changes.
Repeat this process for each Part 2 question where the impact has been identified as potentially moderate to large or where
there is a need to explain why a particular element of the proposed action will not, or may, result in a significant adverse
environmental impact.
Provide the reason(s) why the impact may, or will not, result in a significant adverse environmental impact
For Conditional Negative Declarations identify the specific condition(s) imposed that will modify the proposed action so that
no significant adverse environmental impacts will result.
Attach additional sheets, as needed.
Determination of Significance - Type 1 and Unlisted Actions
SEQR Status: Type 1 Unlisted
Identify portions of EAF completed for this Project: Part 1 Part 2 Part 3
Agency Use Only [IfApplicable]
Project :
Date :
FEAF 2019
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Upon review of the information recorded on this EAF, as noted, plus this additional support information
and considering both the magnitude and importance of each identified potential impact, it is the conclusion of the
as lead agency that:
A. This project will result in no significant adverse impacts on the environment, and, therefore, an environmental impact
statement need not be prepared. Accordingly, this negative declaration is issued.
B. Although this project could have a significant adverse impact on the environment, that impact will be avoided or
substantially mitigated because of the following conditions which will be required by the lead agency:
There will, therefore, be no significant adverse impacts from the project as conditioned, and, therefore, this conditioned negative
declaration is issued. A conditioned negative declaration may be used only for UNLISTED actions (see 6 NYCRR 617.7(d)).
C. This Project may result in one or more significant adverse impacts on the environment, and an environmental impact
statement must be prepared to further assess the impact(s) and possible mitigation and to explore alternatives to avoid or reduce those
impacts. Accordingly, this positive declaration is issued.
Name of Action:
Name of Lead Agency:
Name of Responsible Officer in Lead Agency:
Title of Responsible Officer:
Signature of Responsible Officer in Lead Agency: Date:
Signature of Preparer (if different from Responsible Officer) Date:
For Further Information:
Contact Person:
Address:
Telephone Number:
E-mail:
For Type 1 Actions and Conditioned Negative Declarations, a copy of this Notice is sent to:
Chief Executive Officer of the political subdivision in which the action will be principally located (e.g., Town / City / Village of)
Other involved agencies (if any)
Applicant (if any)
Environmental Notice Bulletin: http://www.dec.ny.gov/enb/enb.html
Page 2 of 2
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Part 3 – Evaluation of the Magnitude and Importance of Project Impacts
Determination of Significance
Cornell Game Farm Road Field Hockey Field
State Environmental Quality Review
Full Environmental Assessment Form
Action(s): Site Plan Approval, Special Permit, Area Variances, Sewer Exemption
Location: Game Farm Road, Tax Parcel No.’s 62.-2-4, 62.-2-5, and 62.-2-6
Lead Agency: Town of Ithaca Planning Board
Involved Agencies: Town of Ithaca Zoning Board of Appeals, Town of Ithaca Town Board
Description: The project involves Site Plan Approval, Special Permit, Area Variances, and a Sewer
Exemption for the proposed Cornell Game Farm Road Field Hockey Field project on Game Farm Road,
located immediately east of the existing Cornell soccer fields.
The proposal involves constructing new field hockey facilities in two phases, with phase one including
the conversion of the existing grass practice field into a synthetic turf field along with construction of
a new driveway, formalized parking area, pedestrian amenities, and two support facilities (a 1,700 +/-
square foot restroom/team room building, and a 480 +/- square foot press box). Phase two involves
the construction of a clubhouse for the field hockey team, with locker rooms, meeting rooms,
physical therapy rooms, lounge, toilets, showers, and indoor synthetic turf training space. Phase two
is projected to be constructed within five years of the athletic field installation. The project also
includes new lighting, landscaping, stormwater facilities, and other site improvements.
The Planning Board will consider granting Site Plan Approval and Special Permit for the project. The
Zoning Board of Appeals will consider area variances related to light pole height and fence height. The
Town Board will consider approving a sanitary sewer exemption, as the project includes construction
of an onsite wastewater treatment system rather than connecting to an existing municipal system.
The proposed action is a Type I Action, pursuant to the New York State Environmental Quality Review
Act, 6 NYCRR Part 617, and Chapter 148 of the Town of Ithaca Code regarding Environmental Quality
Review, because the proposal involves an activity, other than the construction of residential
facilities, that involves the physical alteration of 10 acres (6 NYCRR 617.4 (b) (6) (i)), and parking for
100 vehicles (Town Code 148-5.C (3)).
1. Impact on Land
e. The proposed action may involve construction that continues for more than one year or in
multiple phases.
f. The proposed action may result in increased erosion, whether from physical disturbance or
vegetation removal (including from treatment by herbicides).
Briefly describe the impact on land: The existing project site consists of several large parcels,
collectively approximately 123+/- acres in size, that are owned by Cornell University and utilized for
various educational purposes. The properties are bound on the north by Cascadilla Creek, on the
south by Ellis Hollow Road (CR 110), on the east by Game Farm Road (CR 173), and on the west by the
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existing McGovern soccer fields, the Booth baseball field, and inactive agricultural fields. The East Hill
Plaza/Summerhill Apartments are located approximately 3,000 feet west of the proposed project.
The project site has been utilized for many years as a grass practice field for the Cornell University
soccer program. The existing field, along with the adjacent soccer fields, were granted final site plan
approval by the Planning Board in August 2003.
The proposed project will involve two phases (described on page 1 above), with Phase I expected to
take approximately six months to complete. Phase 2 is not expected to be constructed for another
several years. However, the proposed septic system and stormwater management system will be
sized to accommodate both project phases. This environmental assessment addresses as much of the
full project buildout as is currently foreseeable. The Planning Board, as Lead Agency, will evaluate
future project phases and reassess the environmental impacts of future phases once they are
proposed.
The Phase 1 portion of project will generate an expected 300 truck trips over a two-month period.
The application materials explain that truck traffic associated with Phase 1 will utilize Interstate 81
North or South, with trucks leaving the site heading north using NYS Route 366/Dryden Road, and
those heading south using Tompkins County roads.
The potential for increased erosion and proposed mitigations related to the physical disturbance
associated with the project are evaluated in #3 below. Based on the above information, impacts
identified in this section can be considered small in magnitude.
3. Impact on Surface Water & 5. Impact on Flooding (sections combined due to related impacts)
d. The proposed action may involve construction within or adjoining a freshwater or tidal wetland,
or in the bed or banks of any other water body.
h. The proposed action may cause soil erosion or otherwise create a source of stormwater discharge
that may lead to siltation or other degradation of receiving water bodies.
i. The proposed action may affect the water quality of any water bodies within or downstream of
the site of the proposed action.
j. The proposed action may involve the application of pesticides or herbicides in or around any
water body.
k. The proposed action may require the construction of new, or expansion of existing, wastewater
treatment facilities.
5. Impact on Flooding)
d. The proposed action may result in, or require, modification of existing drainage patterns.
Briefly describe the impact on surface water and flooding: Cascadilla Creek is located along the
northern edge of the project site and is regulated by the Town of Ithaca Stream Setback Law, which
requires a 100’ setback from the stream for development of structures and certain land disturbing
activities. Most of the proposed improvements will be located at least 400+/- feet from the bank of
Cascadilla Creek, however a small portion of the extended detention shallow wetland (proposed for a
stormwater practice and explained below), will encroach approximately 25+/- feet into Zone 2 of the
setback (the zone farthest from the stream). This is permitted per the Town Code, §270-219.5. E (5)
b), which allows the construction of stormwater ponds and wetlands in stream setback Zone 2.
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The application materials state that the project site drains to Cascadilla Creek and that “if necessary,
a professional will apply pesticides and herbicides to control unwanted vegetation and pests.”
However, the project will include erosion and stormwater controls noted below, along with the use of
Integrated Pest Management practices that will mitigate potential pesticide impacts to the creek.
There will be no pesticide application in or around the proposed extended detention shallow
wetland.
Soil Erosion, Water Quality/Quantity, & Flooding: The project involves earth-moving activities related
to grading and preparing the site for the construction of the field, buildings, access drive, parking
area, landscaping, septic system, and stormwater practices. The application materials state that the
proposal will physically disturb 12+/- acres, although the increase in impervious area will only be
3.5+/- acres.
To minimize soil erosion, the proposal includes an erosion and sedimentation control plan with silt
fence, stabilized construction entrance, and other standard erosion control measures that will
minimize soil tracking off-site and control dust.
Regarding water quality treatment for the synthetic turf field, all water falling on the field will
infiltrate through the field itself, which will not contain any infill of any kind. The applicant has chosen
the “Greenfields TX Pro Plus” product manufactured by TenCate, which is comprised of UV-resistant,
low density polyethylene monofilament fibers looped through a woven backing cloth. The turf
product is PFAS-free (PFAS means perfluoroalkyl and polyfluoroalkyl substances) and consists of
recycled plastics, recycled rubber, and a binder material. The proposed turf will comply with NYS
Department of Environmental Conservation (DEC) and US Environmental Protection Agency (EPA)
laws and regulations, including the requirements of the NYS Carpet Collection Program Law,
Environmental Conservation Law §§ 27-3301 through 37-3319, Section 27-3313 states that “no
carpet sold or offered for sale in the state shall contain or be treated with PFAS substances for any
purpose.” The applicant will comply with this requirement even though it is not effective until the
end of 2026. The applicant will also recycle the turf at its end of life.
Runoff from the turf field will convey to a proprietary stormwater filter practice that uses a series of
high surface area membrane filter cartridges capable of removing physical particulates of 0.025
millimeters (25 micrometers) or larger. The application materials note that most analytical methods
can reliably detect microplastic particles as small as 20 to 50 micrometers. The proposed stormwater
filtration system is therefore expected to capture and remove microplastics from stormwater runoff
off the field to sizes that are consistent with what is measurable.
To provide water quality and quantity treatment of stormwater runoff for the rest of the project, the
applicant proposes to construct an extended detention shallow wetland, which will replace two
existing small stormwater wet ponds located to the north that were constructed with the McGovern
soccer field project (2003). This, along with two proposed bioretention filters, will capture and treat
runoff, and provide water quantity reduction as well. The applicant has submitted a Full Stormwater
Pollution Prevention Plan (SWPPP) to the Town’s Engineering Department for their review and
approval. The applicant has been working with the Engineering Department to provide additional
calculations and details that meet NYS DEC permitting requirements.
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The nearest municipal sewer main is located more than 3,000+/- feet west of the project, on
Summerhill Lane. The applicant is therefore proposing an onsite wastewater treatment system,
consisting of a 3,500-gallon septic tank and mound absorption bed. The mound absorption system
will be located along the south side of the proposed parking lot and has been sized using the NYS DEC
Design Standards for Intermediate Sized Wastewater Treatment Systems. As noted above, the
proposed system is designed to accommodate all phases of the project. The private septic system
requires a Sanitary Sewer Exemption authorization from the Town Board per Town Code § 214-5,
along with a State Pollution Discharge Elimination System (SPDES) permit from the NYSDEC, and an
Onsite Wastewater Treatment System construction permit from Tompkins Whole Health.
Though the proposed septic system and leach field area cover significant space above ground, it is
still limited in its capacity and would not induce commercial and residential development as
municipal water and sewer availability would. Additionally, the proposed septic system is not located
within a floodway or floodplain; the average depth to bedrock is more than ten feet in the area; and
the proposed system/leach field is located more than 750+/- feet from Cascadilla Creek and the
proposed stormwater wetland and biofiltration practices.
Based on the above information, impacts identified in this section can be considered small in
magnitude.
7. Impact on Plants and Animals
j. Other Impacts.
Briefly describe the impact on plants and animals: The project site has been previously disturbed with
the development of athletic facilities, namely soccer fields, baseball fields, parking areas, access
drives, lighting, and stormwater management facilities. The NYS DEC Nature Explorer Mapping
program identified two species of dragonfly and two species of plants that have been historically
confirmed in the area. The Midland Clubtail and Mocha Emerald dragonflies were last confirmed in
the area in 1894 and 1926, respectively. The Delicate Rabbit Tobacco (endangered) and the Three
Birds Orchid (threatened) were last confirmed in 1919 and 1922, respectively.
The Midland Clubtail inhabits medium to large, moderate to rapid-flowing rivers and streams. Mocha
Emeralds inhabit small, shaded streams in forested areas that are about 1-3 yards wide with sand,
gravel, or rocky substrates. These habitat characteristics are potentially located within the adjacent
Cascadilla Creek stream and streamside areas of the property but are not located within the project
site.
Similarly, the Delicate Rabbit Tobacco is found in dry woods and openings (occasionally along
roadsides); and the Three Birds Orchid is found in forests, shrublands, and woodlands. If present, they
would also likely be located in the woods within and surrounding Cascadilla Creek to the north of the
project site.
There is no evidence of the presence of the aforementioned plant and animal species on the
proposed project site. Given that the species have not been confirmed on the project site for at least
99 years, and that the site has been previously disturbed and does not contain the habitat to support
such species, impacts identified in this section can be considered small in magnitude.
5
8. Impact on Agricultural Resources
h. Other Impacts.
Briefly describe the impact on agricultural resources: The specific project site contains an existing
grass soccer field, a gravel drive, and a small gravel parking area. The remainder of the project site is
maintained as mowed grass, surrounded by fallow agricultural fields. There are two existing soccer
fields and a synthetic turf baseball field on two adjacent properties (stormwater and septic facilities
associated with the field hockey project will be located on these parcels). None of the properties have
been used for agricultural purposes for many years and are not located within or near a Tompkins
County Agricultural District.
The Town of Ithaca has an Agriculture and Farmland Protection Plan that was adopted in November
2011. The plan contains a map that shows a strip of land classified as “Farmland of Statewide
Importance” that is approximately 16+/- acres in total across the three properties (attached).
However, according to the Agriculture and Farmland Protection Plan, this project site has not been
targeted for agricultural easements or any other agricultural protection. The proposed project will
not impact the 16+/- acre strip of land.
Based on the above information, impacts identified in this section can be considered small in
magnitude.
9. Impact on Aesthetic Resources
c. The proposed action may be visible from publicly accessible vantage points: seasonally (e.g.,
screened by summer foliage, but visible during other seasons), and/or year-round.
d. The situation or activity in which viewers are engaged while viewing the proposed action is
routine travel by residents, including to and from work, and recreational or tourism activities.
f. There are similar projects visible within 0-1/2 mile of the proposed project.
Briefly describe the impact on aesthetic resources: The proposed field hockey field will replace an
existing grass soccer field, located near the edge of Game Farm Road. Those who commute to work in
Ithaca via Ellis Hollow Road will likely pass the field on their way to and from work. The nearest
development is on the adjacent parcel, which contains two lighted soccer fields and associated
structures. The parcel to the west of the soccer fields contains the Booth synthetic turf baseball field,
with associated buildings, lighting, signage, parking area, and access drive off Ellis Hollow Road. The
new field and associated structures will be visible from Ellis Hollow Road and Game Farm Road year-
round.
The Town of Ithaca and Tompkins County have established Scenic Resources Inventories that identify
significant views in the East Hill/Cornell area. The town’s inventory does identify the corner of Ellis
Hollow and Game Farm Roads as “noteworthy” (Chapter 3, view #18). However, the view is not
considered significant and therefore was not included in the list of significant views to protect.
Although the Booth baseball field is within this viewshed, the proposed field hockey field is not. There
are no other identified scenic resources around the project site that would be impacted by the
proposed development.
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Based on the above information, impacts identified in this section would be considered small in
magnitude.
10. Impact on Historic and Archaeological Resources
a. The proposed action may occur wholly or partially within, or substantially contiguous to, any
buildings, archaeological site or district which is listed on the National or State Registers of
Historic Places, or that has been determined by the Commissioner of the NYS Parks, Recreation,
and Historic Preservation to be eligible for listing on the State Register of Historic Places.
b. The proposed action may occur wholly or partially within, or substantially contiguous to, an area
designated as sensitive for archaeological sites on the NY State Historic Preservation Office
archaeological site inventory.
Briefly describe the impact on historic and archaeological resources: The project site is not located
on or adjacent to any buildings or areas officially listed on the National or State Registers of Historic
Places. However, an archaeological investigation for the Cornell soccer field project on the same
property identified a building associated with a 1930’s Civilian Conservation Corps camp that was
located off Game Farm Road, along with the remains of three nineteenth century farms off Ellis
Hollow Road, and several Native American sites near Cascadilla Creek.
The applicant for the 2021 Booth baseball field project hired Panamerican Consultants Inc. to perform
a Phase 1A Cultural Resources Investigation and Phase 1B Archaeological Survey to determine if such
archaeological resources existed on the three parcels associated with the current project site. The
purpose of the Phase 1A investigation was to research the area to identify if previously recorded
archaeological resources would be impacted by the baseball field project. Based on the results of the
Phase 1A investigation, the baseball field project did not impact previously identified resources. The
purpose of the Phase 1B survey was to determine the presence of any new cultural resources in the
project area. The Phase 1B survey did not unearth Native American artifacts or other artifacts of
historical significance. As a result, the Panamerican Consultants did not recommend further
investigation.
An Archaeological Survey addendum was completed by a consultant with the Public Archaeology
Facility in Binghamton in 2024 in association with the current field hockey field project. The results of
the survey were included in the application materials for the project and provided to the Planning
Board in November 2024. One of the statements in the addendum referenced a previously-
investigated site that is located close to the proposed extended detention shallow wetland
stormwater facility. The language from the addendum states: “The historic component at Locus 2 of the
Cascadilla Creek 2 Site is still within the original 2003 to 2005 project APE for the Cornell University Athletic
Fields, is intact, and in an undisturbed setting. This component area produced an abundance and diversity of
early historic artifacts, possibly associated with a settler cabin or camp, and has the potential to produce
significant archaeological information about the early historic period for the Town of Ithaca. Although this
component area is well outside of the current addendum APE summarized for this report, we are
recommending that this specific section of Locus 2 be maintained as an existing agricultural field and not
subject to construction connected with the university athletic fields (or any other future development projects).
As such, the NYS SHPO is likely to request an official avoidance plan from the university outlining the methods
in which the early historic component at Locus 2 of the Cascadilla Creek 2 Site will be protected from future
athletic field developments.”
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All documents prepared by the 2024 consultant were submitted to NYS Office of Parks, Recreation,
and Historic Preservation (OPRHP) via the Cultural Resources Information System. NYS OPRHP
reviewed the reports, determined that no archaeological sites were identified, and concurred with
the recommendation that no additional archaeological work would be necessary for the project.
Bradley W. Russell, Ph.D. Historic Preservation Specialist with OPRHP, stated in his letter to the
applicant’s archaeological consultant on October 18, 2024, that “OPRHP has reviewed the Addendum
Phase I Archaeological Survey report for the Addendum to the Cornell University Athletic Fields Project
24PR08775) prepared by The Public Archaeology Facility, Binghamton University, Consulting
Archaeologists (September 2024; 24SR00535). OPRHP concurs with the report recommendation that
no additional archaeological investigation is warranted.”
Although OPRHP recommended no additional archaeological investigation, there should be extra
protection of the “CC2 Locus 2” area of the site (see attached map) during construction of the shallow
wetland/stormwater facilities associated with the field hockey field project. Based on the above
information, impacts identified in this section would be considered small in magnitude.
13. Impact on Transportation
e. The proposed action may alter the present patter of movement of people or goods.
Briefly describe the impact on transportation: The project involves replacing an existing gravel
entrance off Game Farm Road to access the field hockey field, along with replacing the existing
informal parking lot with a new, paved 120-space parking lot (plus two bus parking pull off spaces), to
accommodate the field hockey and soccer field uses. Other improvements include pedestrian
sidewalks around the parking lot to the soccer fields and new field hockey field, eight bicycle racks
that will provide 16 bicycle parking spaces, and a proposed 20-foot wide turnaround access.
The existing circulation is characterized by gravel pathways that connect informal parking to the
existing McGovern soccer fields and building. The proposal will formalize the parking and improve the
connections and access for all users, with paving and striping, access lanes that are wide enough to
accommodate fire and emergency vehicles, and ADA-compliant sidewalks and parking spaces. The
proposal includes landscaping with native plantings to provide canopy cover to walkways and parking
spaces.
The application materials include a traffic analysis for the project. According to the analysis, which
evaluated the parking needs for both soccer and field hockey team uses, field hockey practices will
generate up to 18 vehicle trips between 6:30am and 9:00am, Monday through Friday. Field hockey
competitions could generate up to 74 car round trips and two buses in the afternoon/evening hours.
Soccer practice (men’s or women’s) would generate 21.5 trips on either end of the 5:00pm to 7:00pm
time period, for a total of 43 round trips if both teams practice simultaneously. [Note that the soccer
field use is existing, and its impact on traffic was previously analyzed when the soccer fields were
approved.]
According to the materials, the busiest time period will occur if a field hockey game coincides with
practices by both soccer teams, which could happen on a weekend afternoon/evening. The highest
demand would generate up to 117 vehicle trips on a fall weekend between the hours of 4:00pm and
7:00pm. This would be considered a small addition of traffic, on a weekend evening (no conflict with
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typical workday traffic) and would not impact traffic flow for users of Game Farm Road or Ellis Hollow
Road, which are both county roads.
Like the previous baseball field application, there are no minimum parking requirements established
in the Town Code for this type of project and therefore no mechanism for the Planning Board to
consider a reduction in required parking. The project is in a residential zone, and the Town Code is
silent in terms of parking requirements for an athletic field in a residential zone. The proposed
number of parking spaces is based upon detailed projected use for the athletic field functions – which
accommodates women’s and men’s soccer practices and field hockey practices and games. Field
hockey practices are held in the morning and soccer practices are held in the afternoon, leaving a low
likelihood of parking overlapping (except in the case outlined above, which would require up to 117
parking spaces, per the traffic analysis).
Given that the project will be constructed on a site that is more than 100 acres in size, there is
plenty of space to add future parking if necessary. The applicant would need to come back to the
Planning Board for a site plan modification review and approval should they require future parking
beyond five more spaces. This would involve another environmental review and analysis of
stormwater impacts associated with the additional impervious surface.
Based on the above information, impacts identified in this section would be considered small in
magnitude.
15. Impact on Noise, Odor, and Light
a. The proposed action may produce sound above ambient levels established by local regulation.
d. The proposed action may result in light shining onto adjoining properties.
Briefly describe the impact on noise and light: The project will create noise impacts during
construction of the access road, parking, buildings, and related infrastructure. These impacts will be
temporary and will cease once the project is completed.
The application materials include an environmental sound analysis to evaluate the proposed public
address (PA) system for the project. The PA system has been designed to cover the playing field and
bleachers while minimizing sound to surrounding areas. The system includes seven loudspeakers
mounted on three poles to the east side of the field (facing away from Game Farm Road, and toward
the field). Three of the speakers will cover the playing field, and the other four will cover the
spectator area, including the bleachers and sidelines. It is expected that the PA system will emit
sound at 84dB at the center of the playing field, according to the CadnaA modeling software that was
used to analyze sound for the project.
The calculated sound levels shown in Figure 2 of the sound analysis indicate that sound drops from
84dB in the center of the field to 60dB immediately across Game Farm Road. The nearest residence is
located approximately 1,600+/- feet (1/3 mile) south of the proposal, on the east side of Game Farm
Road, in the Town of Dryden. Figure 2 indicates that sound will be at 50bB at this residence, as well as
at most residences along the south side of Ellis Hollow Road (there are four residences along Ellis
Hollow Road in the affected area). Sound will also be at 50bB for residents of the Summerhill
Apartment complex, located approximately ½ mile west of the project.
9
According to a noise decibel level comparison chart created by Yale Environmental Health and Safety
Office, 50dB is the equivalent to something between the sound of a suburban area at night and the
hum of a household refrigerator. However, the Town of Ithaca does not regulate sound/noise in
decibel levels. The Town of Ithaca noise ordinance prohibits “unreasonable noise,” defined as “any
excessive or unusually loud sound which either annoys, disturbs, injures, or endangers the comfort,
repose, health, peace, or safety of a reasonable person of normal sensitivities.”
It is acknowledged from previous environmental reviews in this area of the town that residents who
live along Game Farm Road just over the Town of Ithaca/Town of Dryden line have expressed concern
about the noise from the existing soccer fields. It is possible that sound impacts could be exacerbated
if soccer practices occur at the same time as field hockey games (noted above, weekend
afternoons/evenings between 4:00pm and 7:00pm) and/or if field hockey practices during the
morning hours (6:30am to 9:30am) are considered a nuisance to neighbors. Although the proposal is
not expected to create significant noise impacts, the Planning Board has the authority through the
environmental and site plan review and special permit process to control noise associated with
construction and other activities. The board could mitigate potential adverse sound impacts in this
case by limiting the PA system use to certain times of the day, certain days of the week, or by some
other combination of techniques.
In terms of lighting, the project includes four 70-feet tall athletic field light poles (two on the east side
and two on the west side of the field) and 22, 20-feet tall parking lot light poles. Based on the
submitted Lighting Plans, Sheets L6-01, L6-02, and L6-03, the proposed lighting will comply with most
of the requirements of the Town Outdoor Lighting Law (Town Code §270-173). It is unclear from the
submission whether the shielding for the proposed athletic field light poles comply with Town Code
270-173-9.
The law requires all lighting to be fully shielded and angled; and according to page 13 of the
application report, the lighting for the field will have a “sharp cutoff” and not a “fully shielded”
luminaire. This needs to be clarified. Of note, there are no residences located immediately across the
road from the project on Game Farm Road; and the nearest residences on the west side of the
project are located ½ mile west, on Summerhill Lane. Based on the photometric information
provided, these residences are unlikely to be affected by potential light glare associated with the
project. However, as in the noise impact section above, the Planning Board could mitigate potential
adverse lighting impacts by limiting hours of operation to certain times of the day, certain days of the
week, or by some other combination of techniques.
The specification sheets for the parking lot lights indicate that the LED lights can be 3000K, 4000K, or
5000K. As noted in other environmental reviews, the Outdoor Lighting law is currently silent in terms
of LED color temperature, which equates to the perceived color of a light (warmer yellow lights
versus cooler blue/white lights). Wherever possible, the Planning Board has been following the
recommendations in the Tompkins County Environmental Management Council LED Advisory
Guidelines, which suggest streetlighting and other outdoor lighting have no more than a 3000K color
temperature (toward yellow or warm). For this project, it will not be possible for the applicant to
modify the required color temperature for the field lights, but the applicant should consider using
LEDs with a color temperature of 3000K for the parking lot lights, particularly in this part of Game
Farm Road, where there is low to moderate ambient lighting.
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Based on the above information, impacts identified in this section would be considered small in
magnitude.
16. Impact on Human Health
f. The proposed action has adequate control measures in place to ensure that future generation,
treatment, and/or disposal of hazardous wastes will be protective of the environment and human
health.
Briefly describe the impact: The project includes the replacement of a natural grass athletic field with
a synthetic turf field. The proposed turf will comply with NYS DEC and US EPA laws and regulations,
including the requirements of the NYS Carpet Collection Program Law, Environmental Conservation
Law §§ 27-3301 through 37-3319, Section 27-3313 states that “no carpet sold or offered for sale in
the state shall contain or be treated with PFAS substances for any purpose.” The applicant will
comply with this requirement even though it is not effective until the end of 2026. As stated in a
previous section above, the proposed field will not contain any infill of any kind. The applicant has
chosen the “Greenfields TX Pro Plus” product manufactured by TenCate, which is comprised of UV-
resistant, low density polyethylene monofilament fibers looped through a woven backing cloth. The
turf product is PFAS-free and consists of recycled plastics, recycled rubber, and a binder material.
The application materials state the turf blades for the selected turf product are 100% linear low
density polyethylene. Low density polyethylene is also used for food packaging, packaging film,
squeezable bottles, pipes/tubing, and medical/health care items. The application materials state that
since polyethylene is made from a polymer that is stable at high temperatures, it is inert and is not
associated with any known health effects, nor is it considered to be carcinogenic by national and
world health agencies.
The application materials further state the selected turf product also contains additives that include
heavy metal-free pigments, dulling agents, and UV stabilizers which are encapsulated in the polymer,
meaning that exposure to them does not occur and they therefore do not pose a health concern.
Regarding heat issues, the application materials state that while synthetic turf field surfaces do get
warmer than natural turf field surfaces, air temperatures above synthetic turf surfaces warm only
marginally more than those above natural turf field surfaces, and synthetic field surfaces do not
retain heat once daytime heating is discontinued. These differences are substantially minimized on
cloudy days and do not exist on overcast days. In that respect, synthetic turf fields are different than
urban systems (aggregate buildings, roof tops, and pavement) which are associated with contributing
to heat island effects because those materials continue to release heat well into the nighttime hours.
The project will convey stormwater runoff to a proprietary stormwater filter practice that uses a
series of high surface area membrane filter cartridges capable of removing physical particulates of
0.025 millimeters (25 micrometers) or larger. The application materials note that most analytical
methods can reliably detect microplastic particles as small as 20 to 50 micrometers. The proposed
stormwater filtration system is expected to capture and remove microplastics from stormwater
runoff off the field to sizes that are consistent with what is measurable.
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Finally, the applicant is committed to recycling the synthetic turf at the end of its life. Recycling
facilities under consideration include Turf Recyclers in Rockland Maryland (opening May 2025) and
re[TURN] Reclamation Program in Dalton, Georgia.
Based on the above information, impacts identified in this section would be considered small in
magnitude.
17. Consistency with Community Plans
c. The proposed action is inconsistent with local land use plans or zoning regulations.
Briefly describe the impact: The project is consistent with the Town Comprehensive Plan and Future
Land Use Map but requires area variances by the Zoning Board of Appeals. These variances are
needed because Cornell University is an educational/institutional use in a residential zone, which
occurs because the Town of Ithaca doesn’t currently have an Institutional zoning designation. Ithaca
College, Cornell University, and other institutional uses are therefore restricted to residential height
and area requirements. This project contains light poles that are required to be much taller than a
residential structure (§270-59 of Town Code requires a structure height not to exceed 30 feet tall,
where the proposed external light poles are approximately 70 feet in height and the proposed
camera pole is 35 feet in height). The project also requires fence heights associated with the athletic
field that wouldn’t typically be found on a residential property (§270-223, of Town Code, requires a
maximum fence height of 6 feet, where the fence proposed for the netting located on the north and
south sides of the field is 30 feet). The proposed variances are not expected to create significant
adverse environmental impacts, given the location of the project in an area with other athletic fields
with similarly tall light poles and fences and not located within or near a significant view, as identified
in the Town of Ithaca and Tompkins County Scenic Resources Inventories.
Based on the above information, impacts identified in this section would be considered small in
magnitude.
Staff Recommendation, Determination of Significance
A negative determination of environmental significance is recommended for the action as proposed,
based on review of the materials submitted for the proposed action, the information above, and
analysis of the magnitude and importance of the project impacts. Once Phase two project details are
proposed, the Planning Board, as Lead Agency, will look at whether the environmental review should
be reconsidered.
Lead Agency: Town of Ithaca Planning Board– Site Plan Approval, Special Permit
Involved Agencies: Town of Ithaca Zoning Board of Appeals- Variances
Town of Ithaca Town Board– Sewer Exemption
Reviewer: Christine Balestra, Senior Planner
Review Date: March 11, 2025
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User Defined Results Report
Criteria: Selected Map Area
New York Nature Explorer
http://www.dec.ny.gov/natureexplorer/
Common Name
State
Distribution
Status
Protection Status ConservationRankSubgroup
Federal State Global
Year Last
Documente
Animal: Dragonflies and Damselflies
Midland Clubtail Dragonflies S3Historically
Confirmed
G51894
Gomphurus fraternus
Mocha Emerald Dragonflies S2S3HistoricallyConfirmedG51926
Somatochlora linearis
Plant: Flowering Plants
Delicate Rabbit Tobacco Asters, Goldenrods and
Daisies SHHistoricallyConfirmed G4G5T3?Endangered1919
Pseudognaphalium
micradenium
Three Birds Orchid Orchids S2HistoricallyConfirmed G4?T4?Threatened1922
Triphora trianthophoros ssp.
trianthophoros
Page 1 of
3/7/25 3:40 PM
2NewYorkStateDepartmentofEnvironmentalConservation
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New York Nature Explorer
Common Name
State
Distribution
Status
Protection Status ConservationRankSubgroup
Federal State Global
Year Last
Documente
New York State Department of Environmental Conservation
3/7/25 3:40 PM
Page 2 of 2
Note: Restricted plants and animals may also have also been documented in one or more of the Towns or Cities in which
your user-defined area is located, but are not listed in these results. This application does not provide information at the level
of Town or City on state-listed animals and on other sensitive animals and plants. A list of the restricted animals and plants
documented at the corresponding county level can be obtained via the County link(s) on the original User Defined Search
Results page. Any individual plant or animal on this county’s restricted list may or may not occur in this particular user-defined
area.
This list only includes records of rare species and significant natural communities from the databases of the NY Natural
Heritage Program. This list is not a definitive statement about the presence or absence of all plants and animals, including
rare or state-listed species, or of all significant natural communities. For most areas, comprehensive field surveys have not
been conducted, and this list should not be considered a substitute for on-site surveys.
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Town of Ithaca
Agricultural and Farmland Protection Plan
Farmland Targeted for Protection
µ010.5
Mile
FINAL
MAP 9
Map Produced by:
Town of Ithaca
Planning Department
November 2011
Data Source:
Town of Ithaca
Planning Department &
Tompkins County Information
Technology Services GIS Division
City of Ithaca
Village of
Cayuga Heights
Vi lla ge o fLansingTownof
Lansing
Town of Ulysses
To
w
n
of
En
fie
l
d
Town of Newfield Town of D anb y
To
w
n
of
D
ry
de
n
Note: Areas identified are approximate.
Privately Owned and
Operated Farmland
Cornell University and
State Owned Agricultural
Research Land
D r y d e n R d
79
79
89
96
13
96B
Bundy Rd
Hayts Rd
Bostwick Rd
King
Rd
W
King Rd E
C
o
d
din
g
to
n
R
d
B urn sRd
Ellis Hollow Rd
For e s t H o me Dr
Hanshaw Rd
Sheffield
Rd
C
ulv
e
r
R
d
Sandbank
Rd
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Town of Ithaca
Agricultural and Farmland Protection Plan
Agricultural Soils
µ010.5
Mile
FINAL
MAP 5
Map Produced by:
Town of Ithaca
Planning Department
November 2011
Data Source:
Town of Ithaca
Planning Department &
Tompkins County Information
Technology Services GIS Division
City of Ithaca
Village of
Cayuga Heights
Vi lla ge o fLansingTownof
Lansing
Town of Ulysses
To
w
n
of
En
fie
l
d
Town of Newfield Town of D anb y
To
w
n
of
D
ry
de
n
USDA Prime Farmland
Farmland of Statewide Importance
D r y d e n R d
79
79
89
96
13
96B
Bundy Rd
Hayts Rd
Bostwick Rd
King
Rd
W
King Rd E
C
o
d
din
gto
n
R
d
B urn sRd
Ellis Hollow Rd
For e s t H o me Dr
Hanshaw Rd
Sheffield
Rd
C
ulv
e
r
R
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Sandbank
Rd
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Soil Map—Tompkins County, New York
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
3/6/2025
Page 1 of 3
46
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380300 380400 380500 380600 380700 380800 380900 381000
380200 380300 380400 380500 380600 380700 380800 380900 381000
42° 26' 28'' N
76
2
7
2
3
W
42° 26' 28'' N
76
2
6
4
7
W
42° 25' 53'' N
76
2
7
2
3
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42° 25' 53'' N
76
2
6
4
7
W
N
Map projection: Web Mercator Corner coordinates: WGS84 Edge tics: UTM Zone 18N WGS84
0 250 500 1000 1500
Feet
0 50 100 200 300
Meters
Map Scale: 1:5,270 if printed on A portrait (8.5" x 11") sheet.
Soil Map may not be valid at this scale.
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MAP LEGEND MAP INFORMATION
Area of Interest (AOI)
Area of Interest (AOI)
Soils
Soil Map Unit Polygons
Soil Map Unit Lines
Soil Map Unit Points
Special Point Features
Blowout
Borrow Pit
Clay Spot
Closed Depression
Gravel Pit
Gravelly Spot
Landfill
Lava Flow
Marsh or swamp
Mine or Quarry
Miscellaneous Water
Perennial Water
Rock Outcrop
Saline Spot
Sandy Spot
Severely Eroded Spot
Sinkhole
Slide or Slip
Sodic Spot
Spoil Area
Stony Spot
Very Stony Spot
Wet Spot
Other
Special Line Features
Water Features
Streams and Canals
Transportation
Rails
Interstate Highways
US Routes
Major Roads
Local Roads
Background
Aerial Photography
The soil surveys that comprise your AOI were mapped at
1:20,000.
Warning: Soil Map may not be valid at this scale.
Enlargement of maps beyond the scale of mapping can cause
misunderstanding of the detail of mapping and accuracy of soil
line placement. The maps do not show the small areas of
contrasting soils that could have been shown at a more detailed
scale.
Please rely on the bar scale on each map sheet for map
measurements.
Source of Map: Natural Resources Conservation Service
Web Soil Survey URL:
Coordinate System: Web Mercator (EPSG:3857)
Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more
accurate calculations of distance or area are required.
This product is generated from the USDA-NRCS certified data as
of the version date(s) listed below.
Soil Survey Area: Tompkins County, New York
Survey Area Data: Version 20, Aug 29, 2024
Soil map units are labeled (as space allows) for map scales
1:50,000 or larger.
Date(s) aerial images were photographed: Apr 1, 2020—Oct 1,
2020
The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor
shifting of map unit boundaries may be evident.
Soil Map—Tompkins County, New York
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
3/6/2025
Page 2 of 3
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Map Unit Legend
Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI
BaC Bath channery silt loam, 5 to
15 percent slopes
2.1 1.6%
BtF Bath, Valois, and Lansing soils,
35 to 60 percent slopes
0.1 0.1%
CdC Chenango gravelly loam, 5 to
15 percent slopes
16.1 12.2%
EbB Erie channery silt loam, 3 to 8
percent slopes
56.6 42.9%
EcA Chippewa and Alden soils, 0 to
8 percent slopes
1.4 1.1%
ErA Erie-Chippewa channery silt
loams, 0 to 3 percent slopes
0.6 0.4%
HsB Hudson silty clay loam, 2 to 6
percent slopes
3.8 2.9%
HsC3 Hudson silty clay loam, 6 to 12
percent slopes, eroded
6.5 4.9%
HsD3 Hudson silty clay loam, 12 to
20 percent slopes, eroded
0.5 0.4%
LaB Langford channery silt loam, 2
to 8 percent slopes
3.0 2.3%
LaC Langford channery silt loam, 8
to 15 percent slopes
8.8 6.6%
LtB Lordstown, Tuller, and Ovid
soils, shallow and very
shallow, 0 to 15 percent
slopes
0.3 0.2%
Mm Madalin mucky silty clay loam 4.6 3.5%
PhB Phelps gravelly silt loam, 3 to 8
percent slopes
3.3 2.5%
RkB Rhinebeck silt loam, 2 to 6
percent slopes
20.4 15.5%
VbB Volusia channery silt loam, 3 to
8 percent slopes
1.1 0.9%
VbC Volusia channery silt loam, 8 to
15 percent slopes
2.7 2.0%
Totals for Area of Interest 132.0 100.0%
Soil Map—Tompkins County, New York
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
3/6/2025
Page 3 of 3
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Tompkins County, New York
CdC—Chenango gravelly loam, 5 to 15 percent slopes
Map Unit Setting
National map unit symbol: 9xl6
Elevation: 600 to 1,800 feet
Mean annual precipitation: 32 to 42 inches
Mean annual air temperature: 45 to 48 degrees F
Frost-free period: 120 to 160 days
Farmland classification: Farmland of statewide importance
Map Unit Composition
Chenango and similar soils:80 percent
Minor components:20 percent
Estimates are based on observations, descriptions, and transects of
the mapunit.
Description of Chenango
Setting
Landform:Terraces, valley trains
Landform position (two-dimensional):Shoulder
Landform position (three-dimensional):Tread
Down-slope shape:Convex
Across-slope shape:Convex
Parent material:Gravelly loamy glaciofluvial deposits over sandy
and gravelly glaciofluvial deposits, derived mainly from
sandstone, shale, and siltstone
Typical profile
H1 - 0 to 8 inches: gravelly loam
H2 - 8 to 26 inches: gravelly silt loam
H3 - 26 to 60 inches: very gravelly loamy coarse sand
Properties and qualities
Slope:5 to 15 percent
Depth to restrictive feature:More than 80 inches
Drainage class:Somewhat excessively drained
Capacity of the most limiting layer to transmit water
Ksat):Moderately high to high (0.57 to 5.95 in/hr)
Depth to water table:More than 80 inches
Frequency of flooding:None
Frequency of ponding:None
Available water supply, 0 to 60 inches: Low (about 4.0 inches)
Interpretive groups
Land capability classification (irrigated): None specified
Land capability classification (nonirrigated): 3e
Hydrologic Soil Group: A
Ecological site: F140XY021NY - Dry Outwash
Hydric soil rating: No
Map Unit Description: Chenango gravelly loam, 5 to 15 percent slopes---Tompkins County,
New York
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
3/6/2025
Page 1 of 2
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Minor Components
Tioga
Percent of map unit:5 percent
Hydric soil rating: No
Howard
Percent of map unit:5 percent
Hydric soil rating: No
Red hook
Percent of map unit:5 percent
Hydric soil rating: No
Braceville
Percent of map unit:5 percent
Hydric soil rating: No
Data Source Information
Soil Survey Area: Tompkins County, New York
Survey Area Data: Version 20, Aug 29, 2024
Map Unit Description: Chenango gravelly loam, 5 to 15 percent slopes---Tompkins County,
New York
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
3/6/2025
Page 2 of 2
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177
Public Archaeology Facility 03PR00922, Addendum Phase 1 Report Page | 42
PB 2025-02-18 (Fled 2/21) Pg. 1
TOWN OF ITHACA PLANNING BOARD
February 18, 2025
The full recording of this meeting is available on the Town’s YouTube Live Meeting page.
Draft Minutes
Present: Caitlin Cameron Chair; Liz Bageant, Bill Arms, Kelda McGurk, and Sara Reynolds
CJ Randall, Director of Planning; Christine Balestra, Senior Planner; Susan Brock, Attorney for the
Town; Nick Quilty-Koval, Planner; David O’Shea, Director of Engineering; Dana Magnason,
Senior Code Officer; Justin McNeal, Civil Engineer
Ms. Cameron opened the meeting at 6:30p.m.
Item 1. Persons to be heard.
Marian Mueller: Field hockey player at a high level, and a coach and officiant in the sport. His
daughter is also on the Cornell women’s field hockey team. He is a strategy management consultant
and is versed in making large complex decisions. He has reviewed the environmental claims and
citations provided to the board by groups opposed to the women’s hockey artificial turf field and
can find that none of these citations empirically connect water-based turf and the environmental
impact. He claims these peer reviewed articles are not relevant to this project. Many do not discuss
artificial turf at all, or they discuss turf with rubber infill. Other articles discuss playground turf. He
claims there are no relevant scientific studies that would cause the board to vote on a positive SEQR
declaration in this case. He argued that the quantity of concerns does not equate quality of evidence
in this case.
Yayoi: Objected strongly to the previous comment. She would like the board to issue a positive
SEQR declaration so more studies can be done on the environmental impact of the artificial turf
field. She is concerned about the influence of Cornell’s Athletics Department in the discussions
around the Meinig Field House Project. She claims that student athletes make up only 5% of the
student population. She cites a petition that was submitted to the board with 1200 community
member signatures opposing the project. She states that many Cornell students are not fully aware
of the environmental and health implications of the installation of the synthetic turf. She urges the
board to stay focused on its duty; to assess the environmental and public health impacts of this
project. She would like the public input process to remain fair and not be dominated by a small
group with special interests.
Jo Broderick: Supports the Game Farm Road field hockey field proposal. She is a former field
hockey player and has played on natural turf fields. Her daughter is on the Cornell field hockey
team as a goalkeeper and as such makes a lot of contact with the field during play. Since she was 8
years old, she has only ever played on artificial turf. Ms. Broderick also looked at the studies and
statements that have been cited against the artificial turf. In her opinion these studies have no
relevance to the current project proposed by Cornell. The turf these studies look at are entirely
different than what is proposed in this project. She is very eco-minded and is of the opinion this
field hockey project is as environmentally responsible as it can be. It is also essential to the
women’s field hockey program at Cornell. She believes scientific evidence does not support the
claim this turf field is environmentally irresponsible and hazardous to the health of the players. She
PB 2025-02-18 (Fled 2/21) Pg. 2
states that the claim the players are unknowing putting their health at risk is patronizing to the
women who play on this field. It is also irresponsible when the science used to justify it is plainly
bogus.
Marsha Dodson: In 2008 she donated the money for the original field hockey field. She played
women’s tennis at Cornell. She spoke about her time at Cornell and the inequity of the quality of the
facilities between men and women’s sports. The current field is at the end of its useful life, and,
without the field, the women will not be able to play. It is difficult for these young women to see the
brand new artificial turf baseball field in the same location where their field is being scrutinized.
She addressed Yayoi’s comment about what the hurry is. The hurry is 30 hard working student
athletes will not have a season if this field does not get approved and built in time. These women
will have to go to other schools. She would like the board to look at the science and not require an
EIS.
Bethany Oleto-Mays: Former assistant professor and student athlete at Cornell. She would like a
careful and thorough environmental review. She believes if Cornell wanted the women’s field
hockey team to have continuous athletic play, they would have presented this project interconnected
with the Meinig Field House project. She read a statement from Cornell that was presented to the
Planning Board to separate these two projects based on their independence and different timelines.
That SEQR segmentation request is now being contradicted by current comments. She states that
the commentors in favor of this field should ask Cornell why they advocated for the decision to
separate these two projects and not have the Planning Board vote on both proposals together. She
encourages the Planning Board to not be pressured by Cornell due to a time constraint. She
continued by addressing the comments regarding scientific studies and stated that although the turf
does not contain rubber infill, all the concerns about microplastic pollution and PFAS are still an
issue. These are concerns she has for the community and athletes who will live with the legacy of
the health impacts these fields will carry.
Gracie Leahy: Junior at Cornell and a member of the women’s field hockey team. She chose
Cornell for the potential and support she receives as a student athlete. Her mother was a Canadian
Olympian on the 1974 women’s field hockey team. Her mother played in the Olympics on artificial
turf. She cites the better play that occurs on an artificial turf field. In consequence, players have
developed special skill sets to take advantage of the type of play you can get on a synthetic turf
field. The game is unrecognizable from previous generations. The current players have only played
on artificial turf and are unable to compete at a high level on anything else. Without the field , the
women’s field hockey program at Cornell will be over.
Ashley Plzak: Sophomore at Cornell and on the women’s field hockey team. She is in support of the
Game Farm Road field. She enjoys the speed and style of play of field hockey and her experience
with the field hockey program so far has been very positive. This new facility is a direct
replacement of what is currently there. They require this water based turf because of the style of
play that is now the standard in the game. Some plays are only possible because of the water based
turf field. This field is vital to the program. She would like the board to support it.
Cari Hills: Cornell class of 1998 and a former field hockey and lacrosse player. She founded the
first women’s alumni association for Cornell women’s field hockey. She played at Scho ellkopf
field. Her daughter Polly was also recruited by Cornell. She believes the continuity of the program
is critical to the hard-working student athletes. She wants to appeal to the human element of
building a strong athletic program and the continuity that it requires to keep it going at a high level
PB 2025-02-18 (Fled 2/21) Pg. 3
for the athletes currently in the program and the recruiting of new athletes for the future. She cites
the community that surrounds the program from parents and other alumni of the program that has
supported her throughout her life. She wants the board to look at both sides of the project and keep
in mind the importance of the human element. She wants the board to make a decision in an
efficient and timely manner so there can be a field installed by the season start.
Item 2. Consideration of Special Permit for the deposit of approximately 5,000 cubic yards of
clean fill behind an existing gravel lot on a 0.6-ac portion of the 45.61-ac property located at 716
Elmira Road. The purpose of the project is to provide a future equipment storage area for the farm
operation on the property. The project is a Type II Action under the State Environmental Quality
Review Act and is not subject to environmental review. The project is located in Tompkins County
Agricultural District #2. George Sheldrake, Owner/Applicant; Cody Sheldrake, Agent.
Mr. Quilty-Koval told the board that this is a Type II Action, so no SEQR is required. Mr.
Sheldrake spoke to the board that they have been filling the site slowly over the years. They would
like to put in larger amounts of fill to complete the existing driveway.
Mr. Arms asked the applicant if this was a new driveway. The applicant responded that the
driveway is existing.
Mr. Quilty-Koval pointed out a change to the draft resolution, requested by Ms. Brock, “Whereas
item 2” should specify the farm management practices and reference the specific Type II language
from 6NYCRR Part 617 that makes the action not subject to environmental review.
PUBLIC HEARING
Public hearing opened at 7:01pm. Public hearing closed at 7:02pm with no comments.
DETERMINATION
Ms. Reynolds asked staff about wetlands. Mr. Quilty-Koval replied that staff uses the DEC maps to
determine any wetland site on the projects. The pond on the site is man made.
PB RESOLUTION 2025-04: Special Permit
Early Bird Farm Fill Project
716 Elmira Road
Tax Parcel No. 33.-2-7.2
WHEREAS:
1. This action is a consideration of the Special Permit for the installation of approximately 5,000
cubic yards of clean fill behind an existing gravel lot located at 716 Elmira Road in a Low
Density Residential (LDR) Zone. The purpose of the project is to provide a future equ ipment
storage area for the farm operation on the property. George Sheldrake, Owner/Applicant; Cody
Sheldrake, Agent,
2. In accordance with 6 NYCRR §617.5 (c)(4), State Environmental Quality Review, “agricultural
farm management practices, including construction, maintenance and repair of farm buildings
and structures, and land use changes consistent with generally accepted principles of farming”
are Type II Actions and not subject to environmental review, and
PB 2025-02-18 (Fled 2/21) Pg. 4
3. The Planning Board, at a public hearing held on February 18, 2025, has reviewed and accepted
as adequate a narrative and a set of drawings entitled “Early Bird Farm, Equipment Storage
Area, 716 Elmira Road,” including Sheets 1-3, prepared by Owen B. Barden (OBB), dated
January 8, 2025, and other application materials, and
4. Project plans, and related information, were duly delivered to the Tompkins County Planning
and Sustainability Department per New York State General Municipal Law §239-l et seq., and
such Department responded in a February 6, 2025, letter from Katherine Borgella, Tompkins
County Commissioner of Planning, pursuant to §239-l, -m, and -n of the New York State
General Municipal Law, determining that the proposed action will have no significant county -
wide or inter-community impact;
NOW THEREFORE BE IT RESOLVED:
1. That the Planning Board hereby finds that the Special Permit standards of Article XXIV Section
270-200, Subsections A – H, of the Town of Ithaca Code, have been met, specifically that:
A. The project will be suitable for the property on which it is proposed, considering the
property’s size, location, and physical site characteristics.
The project is located on the existing Early Bird Farm property and will be constructed
in existing, previously disturbed open grass area.
B. The proposed structure design and site layout are compatible with the surrounding area.
The proposed clean fill and gravel equipment storage area located adjacent to an existing
gravel lot is consistent with the Early Bird Farm operations.
C. Operations in connection with the proposed use do not create any more noise, fumes,
vibration, illumination, or other potential nuisances than the operation of any permitted use
in the particular zone.
The proposed project will produce temporary noise, vibration, and other nuisances
associated with construction and farming related activities. Such nuisances will cease
upon completion of the project.
D. Community infrastructure and services, such as police, fire and other protective services,
roadways, schools, and water and sewer facilities are currently, or will be, of adequate
capacity to accommodate the proposed use.
The community infrastructure and services are of adequate capacity to accommodate the
proposed use.
E. The proposed use, structure design, and site layout comply with all the provisions of the
Town Code and with the Town of Ithaca Comprehensive Plan.
F. The site layout, with proposed vehicular, bicycle and pedestrian access, traffic circulation,
and parking and loading facilities, is sufficient for the proposed use and is safely designed
for emergency vehicles.
PB 2025-02-18 (Fled 2/21) Pg. 5
The project does not include installation of new vehicular, bicycle, and pedestrian
access, or the modification to existing traffic circulation and parking and lodging
facilities. This project includes reinforcing portions of the existing gravel access drive
along Elmira Road for the trucks delivering fill and gravel to the site. All accessways
have been safely designed for emergency vehicles.
G. The project includes sufficient landscaping and/or other forms of buffering to protect
surrounding land uses. Existing vegetation is preserved to the extent possible.
The project does not include removal of existing landscaping onsite or modification to
the existing pond and stream setback areas located north of the proposed equipment
storage area.
H. To the extent deemed relevant by the reviewing Board, the proposed use or structure
complies with all the criteria applicable to site plan review set forth in this chapter,
2. That, pursuant to Town Code Section 270-217.E, the Planning Board hereby finds that the plan
adequately protects the property and surrounding properties from significant adverse
consequences of such deposit or removal, including, when completed, adverse drainage,
erosion, visual or other adverse impacts, taking into account the distance of the operation from
neighboring property and public ways, the possible detriment of such use to the future
development of the land in question, and significant nuisance or detriment of the operation to
neighboring landowners and to the community as a whole, and
3. That the Planning Board hereby grants Special Permit for the proposed Early Bird Farm Fill
Project, with the following conditions:
a. Submission to the Town Engineering Department an updated grading plan, and
b. All Town of Ithaca Engineering Department comments listed in the Engineering
Memorandum, written by Joe Slater, Director of Public Works and Justin McNeal, Civil
Engineer, dated February 11, 2025, must be addressed prior to any Land Development
Activity (as defined by Town Code § 228-5).
Moved: Liz Bageant Second: Bill Arms
Vote: Ayes- Cameron, Bageant, Reynolds, Arms, McGurk
Item 3. Consideration of Preliminary and Final Subdivision Approval for the proposed two-
lot subdivision located at 1360 Slaterville Road. The project includes splitting the existing 2.8+/-
acre parcel into two lots, with one 0.9+/- acre lot that will contain an existing residence, garage, and
barn (Parcel A) and one new 1.9+/- acre vacant lot (Parcel B) that will have access off Harwick
Road and Honness Lane. The project is an Unlisted Action under the State Environmental Quality
Review Act and is subject to environmental review. Montgomery May and Patricia Vandebogart,
Owners/Applicants; Ellen Morris-Knower, Agent.
DISCUSSION
No comments from staff. Ms. Cameron confirmed with staff that lot lines on these lots are not
creating non-conforming conditions. Staff agreed.
PB 2025-02-18 (Fled 2/21) Pg. 6
SEQR Determination
PB RESOLUTION 2025-05: SEQR
Preliminary and Final Subdivision Approval
Slaterville Road Two-Lot Subdivision
1360 Slaterville Road
Tax Parcel No. 60.-1-27
WHEREAS:
1. This is consideration of Preliminary and Final Subdivision Approval for the proposed two -lot
subdivision at 1360 Slaterville Road located in a Medium Density Residential (MDR) Zone.
The project includes splitting the 2.8+/- acre parcel into two lots, with one .9+/- acre lot that will
contain an existing residence, garage, and barn (Parcel A) and one new 1.9+/- acre vacant lot
Parcel B) that will have access off Harwick Road and Honness Lane. Montgomery May and
Patricia Vandebogart, Owners/Applicants; Ellen Morris-Knower, Agent;
2. This is an Unlisted Action for which the Town of Ithaca Planning Board is the lead agency in
the environmental review with respect to the project,
3. The Planning Board on February 18, 2025, has reviewed and accepted as adequate a Short
Environmental Assessment Form (EAF) Part 1, submitted by the applicant, Parts 2 and 3
prepared by Planning staff, a subdivision map entitled “Subdivision Map NO. 1360 Slaterville
Road, Town of Ithaca, Tompkins County, New York” prepared by T. G. Miller P.C., dated
8/12/2024, and other application materials;
4. Town Planning staff has recommended a negative determination of environmental significance
with respect to the proposed Subdivision Approval;
NOW THEREFORE BE IT RESOLVED:
That the Town of Ithaca Planning Board hereby makes a negative determination of environmental
significance in accordance with Article 8 of the Environmental Conservation Law 6 NYCRR Part
617 New York State Environmental Quality Review for the above referenced action as proposed,
based on the information in the EAF Part 1 and for the reasons set forth in the EAF Parts 2 and 3,
and, therefore, an Environmental Impact Statement will not be required.
Moved: Liz Bageant Seconded: Bill Arms
Vote: Ayes- Cameron, Bageant, Reynolds, Arms, McGurk
PUBLIC HEARING
Public hearing opened at 7:14pm. Public hearing closed at 7:15pm with no comments.
DETERMINATION
PB RESOLUTION 2025-06: Preliminary and Final Subdivision Approval
Slaterville Road Two-Lot Subdivision
1360 Slaterville Road
Tax Parcel No. 60.-1-27
PB 2025-02-18 (Fled 2/21) Pg. 7
WHEREAS:
1. This is consideration of Preliminary and Final Subdivision Approval for the proposed two -
lot subdivision at 1360 Slaterville Road located within a Medium Density Residential
MDR) Zone. The project includes splitting the 2.8+/- acre parcel into two lots, with one
9+/- acre lot that will contain an existing residence, garage, and barn (Parcel A) and one
new 1.9+/- acre vacant lot (Parcel B) that will have access off Harwick Road and Honness
Lane. Montgomery May and Patricia Vandebogart, Owners/Applicants; Ellen Morris-
Knower, Agent;
2. This is an Unlisted Action for which the Town of Ithaca Planning Board, as lead agency in
the environmental review with respect to the project, has on February 18, 2025, made a
negative determination of environmental significance, after having reviewed and accepted as
adequate a Short Environmental Assessment Form Part 1, submitted by the applicant, and
Parts 2 and 3 prepared by the Town Planning staff; and
3. The Planning Board on February 18, 2025, has reviewed and accepted as adequate a
narrative, a subdivision map entitled “Subdivision Map NO. 1360 Slaterville Road, Town of
Ithaca, Tompkins County, New York,” prepared by T. G. Miller P.C., dated 8/12/2024, and
other application materials;
NOW THEREFORE BE IT RESOLVED:
1. That the Town of Ithaca Planning Board hereby waives certain requirements for Preliminary
and Final Subdivision Approval, as shown on the Preliminary and Final Subdivision
Checklists, having determined from the materials presented that such waiver will result in a
significant alteration of neither the purpose of subdivision control nor the policies
enunciated or implied by the Town Board; and
2. That the Planning Board hereby grants Preliminary and Final Subdivision Approval for the
proposed subdivision at 1360 Slaterville Road, as shown on the survey map noted in
Whereas #3 above, subject to the following conditions:
a. Prior to signing of the plat by the Planning Board Chair, removal of the two sheds on
Parcel B noted “To Be Removed,” and
b.Submission for signing by the Chairperson of the Planning Board of an original and
three dark lined prints of the approved final subdivision plat, including the original
signature and seal of the registered land surveyor, prior to filing with the Tompkins
County Clerk Office, and submission of a copy of the receipt of filing to the Town of
Ithaca Planning Department.
Moved: Sara Reynolds Second: Liz Bageant
Vote: Ayes- Cameron, Bageant, Reynolds, Arms, McGurk
Item 4. Consideration of Preliminary Site Plan, Special Permit, and Preliminary Subdivision
approval for the proposed Mirabito convenience store with gasoline sales and Burger King drive-
through restaurant, located at 301 Pine Tree Road. The project involves demolishing the existing
PB 2025-02-18 (Fled 2/21) Pg. 8
600+/ square foot gas station building and fuel canopy, and the 2,800+/- square foot former Burger
King building, and redeveloping the site with a new 6,000+/- square foot building containing a
convenience store and restaurant with drive-through; gasoline sales; fuel canopy; electric vehicle
charging stations; stormwater facilities; sidewalks/pedestrian amenities; landscaping; and other site
improvements. This is an Unlisted Action under the State Environmental Quality Review Act and is
subject to environmental review. Cornell University, Owner; James Ballantyne, Napierala
Consulting, PC, Applicant; Brett Hughes, Mirabito Energy Products, Agent.
OVERVIEW
Matt Napieraila, a consultant for the applicant, presented the project to the board.
Ms. Bageant liked how the sidewalk got moved off the road and the cohesiveness of the project. She
asked about utility easements and what could be planted there. The applicant responded that they
are limited as the utility company does not want any excessive root growth interfering with the
lines. Ms. Cameron asked about the process for the easements. Condition “m” on the resolution
addresses easements. The board would like all easements reflected on the final plat.
Ms. Bageant asked about the number of sidewalks on the Ellis Hollow side of the building. Ms.
Cameron also asked about an additional door on that side of the building. The applicant will look
into any discrepancies on the plans and correct them on the final plat.
Ms. Bageant asked if both driveways are compatible with DOT regulations on distance from
intersection. The applicant indicated they have followed all DOT regulations with regard to the
placement of the driveways.
Ms. Bageant asked the applicant and staff about the number of parking spaces required. Ms.
Balestra referenced a parking analysis by the Town for the number of parking spaces based on uses
in East Hill Plaza and explained that the Town does not have a required number of parking spaces
for mixed uses. The applicant indicated the Burger King does not require many spaces, as they are
more focused on drive thru operations post Covid. The Mirabito store requires about 11 parking
spaces in front of the store. There is also more parking in the plaza area. Eight spaces are at the fuel
dispensers, even though they can’t be counted. Ms. Balestra informed the board that there are 8-10
fewer parking spaces than in the proposal submitted in 2023.
Ms. Cameron asked about the planting plan. She wants to know more details about the planting and
mature heights. The applicant pointed out existing trees and the specific varieties of trees on the
water retention and roadside parts of the property. Water tolerance, salt tolerance and deer tolerance
are considered when choosing the landscaping. Ms. Balestra also pointed on that the applicant did
submit the number and caliper of the trees that would be removed. The Norway Spruce that will be
removed is an invasive species.
Ms. Reynolds asked who is responsible for maintaining the plantings. The applicant responded this
would be Mirabito’s responsibility. Ms. Balestra added that there is an inspection at the end of the
project to make sure the plantings are healthy and reflect the plans approved by the board.
Mr. Arms asked about Cornell’s support of the project, as they are the owners of the land. At the
previous discussion Cornell indicated that they did not agree to what was proposed. The applicant
responded that in 2023 the applicant went to Cornell with different iterations of the site. They tried
to get Cornell Planning representatives to respond to the current iteration but have not heard back.
PB 2025-02-18 (Fled 2/21) Pg. 9
Ms. Balestra told the board that she received an email from Kristin Gutenberger that expressed
Cornell’s support for the project.
Mr. Arms asked if all the windows were translucent. The applicant indicated that all the windows
are glass, but some windows are opaque as they look into back-end operations of the establishment.
Ms. Cameron wanted to clarify that there are no architectural design standards that the board can
apply. Ms. Balestra concurred. Ms. Cameron asked about the 3 parapet heights on the front part of
the building. The applicant explained the various heights masked the mechanical units that would be
placed on the roof of the building. She then asked about the material of the parapet. The applicant
replied that they are metal.
Ms. Reynolds asked about the Town’s stance on curbs at the road. The applicant answered that they
will leave what is currently there on Ellis Hollow Road. Curbs will be put in place on the site where
necessary. Ms. Balestra answered that both roads are on county highways and the county is
responsible for approving and maintaining the road edges. The applicant further explained that all
sidewalks on the site are zero reveal sidewalks to eliminate trip hazards. There will be a change in
materials only from the asphalt to the sidewalk. Bollards every 6 feet will prevent cars from parking
onto the sidewalk. Accessibility analysis will be done before final approval.
Ms. McGurk stated that the new design is a big improvement and considered Planning Board
requests from the 2023 version. She wants to know if there is a bike rack area. There is currently no
bike rack, but the applicant will investigate a place for a bike rack. Board discussion ensued
regarding requiring bike racks in the conditions of approval.
Ms. Bageant asked about the storm water retention system and the boulders. She would like to
know if they will be removed. The applicant answered that, due to the proximity of the new
property line, those boulders will most likely be removed. Mr. O’Shea answered that the storm
water system will meet permit conditions by retaining the storm water retention system on the
Burger King lot only. More discussion will occur at the staff level with the applicant.
SEQR DETERMINATION
The Board discussed adding permitting and special approvals from various governmental agencies
to the SEQR.
Board discussion then moved to light spillage and LED color temperatures on the site. Ms. Balestra
told the board that in the past, the lighting required by the board was at a maximum color
temperature of 3000K. There are several areas where 5000K is indicated on the current plans. The
applicant indicated that they would fix that to 3000K, but they may need more light poles. There
may also be a NFPA requirement for the amount of light under a canopy. Mr. O’Shea asked if the
lighting plan was inclusive of any lighted signage and wall packs. The applicant said it was not.
However, there are awnings that will shield those lights. They will comply with the Town’s lighting
requirements. The applicant will update all this information.
PB RESOLUTION 2025-07: SEQR
Preliminary Site Plan/Subdivision, Special Permit
Mirabito Redevelopment Project
301 Pine Tree Road
Tax Parcel No.’s 62.-2-1.121, 62.-2-1.13, 62.-2-1.22
PB 2025-02-18 (Fled 2/21) Pg. 10
WHEREAS:
1. This action is consideration of Preliminary Site Plan, Special Permit, and Preliminary
Subdivision approval for the proposed Mirabito convenience store with gasoline sales and
Burger King drive-thru restaurant, located at 301 Pine Tree Road. The project involves
demolishing the existing 600+/ square foot gas station building and fuel canopy, and the
2,800+/- square foot former Burger King building, and redeveloping the site with a new
6,000+/- square foot building containing a convenience store and restaurant with drive-thru,
gasoline sales, fuel canopy, electric vehicle charging stations, stormwater facilities,
sidewalks/pedestrian amenities, landscaping, and other site improvements. Cornell
University, Owner; James Ballantyne, Napierala Consulting, PC, Applicant; Brett Hughes,
Mirabito Energy Products, Agent,
2. This is an Unlisted Action for which the Town of Ithaca Planning Board is acting as the lead
agency in an uncoordinated environmental review with respect to the project,
3. The Planning Board, on February 18, 2025, has reviewed and accepted as adequate: a Short
Environmental Assessment Form (SEAF) Part 1, submitted by the applicant; Parts 2 and 3
prepared by Town Planning staff; a binder of materials titled “Site Plan Review Materials
For Proposed Mirabito Redevelopment Project, 301 Pine Tree Road, Ithaca, NY, 14850,”
including set of revised drawings titled “Proposed Mirabito Redevelopment Project, 301
Pine Tree Road, Ithaca, NY, 14850, Town of Ithaca, Tompkins County, New York State,”
with sheets C-0, C-1, C-2, C-2.1, C-3 through C-14, prepared by Napierala Consulting,
dated 05 May, 2023 and most recently revised 1/14/2025; architectural plans titled
Convenience Center W/Fuel, Mirabito, Ithaca, NY,” including sheets A-101 through A-
116, prepared by Delta Engineers, Architects & Surveyors, dated 02/06/2025; a subdivision
plat titled “Subdivision Map, For Cornell University Located At, No. 1010 Ellis Hollow
Road and No. 301 Pine Tree Road, Town of Ithaca, Tompkins County, New York,”
prepared by T.G. Miller, P.C., dated 4/17/2023 and revised 6/15/2023; and other application
materials, and
4. The Town Planning staff has recommended a negative determination of environmental
significance with respect to the proposed Site Plan Approval, Subdivision Approval, and
Special Permit;
NOW THEREFORE BE IT RESOLVED:
That the Town of Ithaca Planning Board hereby makes a negative determination of environmental
significance in accordance with Article 8 of the Environmental Conservation Law and 6 NYCRR
Part 617 New York State Environmental Quality Review for the above ref erenced actions as
proposed, based on the information in the EAF Part 1 and for the reasons set forth in the EAF Parts
2 and 3, and, therefore, a Draft Environmental Impact Statement will not be required.
Moved: Bill Arms Seconded: Liz Bageant
Vote: Ayes: Cameron, Bageant, Reynolds, Arms, McGurk
PUBLIC HEARING
Public hearing opened at 8:35pm
PB 2025-02-18 (Fled 2/21) Pg. 11
Ms. Reynolds wanted to know the width of the grass band on the north of the site and if there could
be a third driveway on that site. The applicant answered that Cornell deemed the one driveway on
the North side was adequate and part of the plan for the entire site.
Steffi: Frequently walks down Pine Tree Road and crosses at the crosswalk by the stop sign. She
would like to know if there will be a way to go from that crossing directly to the P&C. Will a
person be able to walk through parcel number 2? She is also concerned about the state of the current
parking lot at the site and would like the lot to be better maintained.
Public hearing closed at 8:40pm
DETERMINATION
Ms. Cameron had concerns about pedestrian safety and access to the Burger King from the east side
of the lot. She felt that pedestrians will cut through the drive through lanes to get to the Burger King
rather than follow the walkway all the way around the building or entering the street entrance of the
convenience store. The applicant explained that he anticipates pedestrians will go through the
convenience store entrance to get to the Burger King, as the interior of the building is open plan and
the Burger King is easily accessible from the convenience store entrance. Ms. Balestra explained
that parcel 2 is owned by Cornell and out of the applicant’s control. The applicant is unable to put a
sidewalk on that side of the property alone.
Ms. Bageant asked the applicant for clarification of the entrances accessible to the public on the
Ellis Hollow Road side of the property. The applicant responded there will be a private employee
entrance to the Burger King and a public entrance to the convenience store.
Ms. Cameron asked about pedestrian accommodation to the rest of East Hill Plaza coming off of
Ellis Hollow Road. The applicant explained that there are some opportunities on the east side of the
lot to put in pedestrian access. However, that would have to involve Cornell as they own the land.
There is also an existing sidewalk on lot 2 although it truncates at lot 2.
Mr. O’Shea addressed the board and explained that the Town has a trail from the Summerhill
development to East Hill Plaza. This is the main access from East to West for pedestrians coming
from residential areas.
Ms. Bageant would like to add some connectivity on the east side of the property if possible. She
believes East Hill Plaza itself is not pedestrian friendly but could be in the future with connectivity
starting with this project.
Ms. McGurk is in favor of this link on the east side of the property for pedestrian access. Discussion
by the board ensued as to require the applicant to create the access in this project or wait until the
development of lot 2.
The applicant addressed the question of parking lot maintenance once the project is completed. The
applicant explained the new parking lot will be done with the best possible materials so it will last a
very long time. It is in Mirabito’s best interest to keep the area maintained and attractive.
Ms. Reynolds asked the applicant about the traffic flow with regard to the fuel trucks. The applicant
explained fueling trucks will enter off of Pine Tree Road and exit onto Ellis Hollow Road. The path
PB 2025-02-18 (Fled 2/21) Pg. 12
of the fuel trucks will be out of the way of any pedestrians, passenger vehicles and the Burger King
drive through.
The Board requested more landscaping along the Ellis Hollow Road side of the site. Ms. Bageant
suggested more landscaping across the rear of the building next to the utility easement, and larger,
more mature trees planted. Ms. Balestra explained to the board that a new condition “b” in the
resolution could include items the board would like to see. Board discussion ensued as to the
wording of a new condition “b” in the resolution, regarding plantings and bike racks on the site.
A small detail on the plans showed a chain link fence on the plans. The applicant indicated this is an
oversight and the fence will be made of materials that will match the building such as cement board.
A condition related to the fence was added to the new condition “b”.
Further discussion by the board and staff to refine the language of the draft resolution.
PB RESOLUTION 2025-08: Preliminary Site Plan/Subdivision, Special Permit
Mirabito Redevelopment Project
301 Pine Tree Road
Tax Parcel No.’s 62.-2-1.121, 62.-2-1.13, 62.-2-1.22
WHEREAS:
1. This action is consideration of Preliminary Site Plan, Special Permit, and Preliminary
Subdivision approval for the proposed Mirabito convenience store with gasoline sales and
Burger King drive-thru restaurant, located at 301 Pine Tree Road. The project involves
demolishing the existing 600+/ square foot gas station building and fuel canopy, and the
2,800+/- square foot former Burger King building, and redeveloping the site with a new
6,000+/- square foot building containing a convenience store and restaurant with drive-thru,
gasoline sales, fuel canopy, electric vehicle charging stations, stormwater facilities,
sidewalks/pedestrian amenities, landscaping, and other site improvements. Cornell
University, Owner; James Ballantyne, Napierala Consulting, PC, Applicant; Brett Hughes,
Mirabito Energy Products, Agent,
2. This is an Unlisted Action for which the Town of Ithaca Planning Board, acting as the lead
agency in an uncoordinated environmental review with respect to the project, has, on
February 18, 2025, made a negative determination of environmental significance, after
reviewing and accepting as adequate a Short Environmental Assessment Form Part 1,
submitted by the applicant, and Parts 2 and 3 prepared by Town Planning staff,
3. The Planning Board, on February 18, 2025, has reviewed and accepted as adequate: a binder
of materials titled “Site Plan Review Materials For Proposed Mirabito Redevelopment
Project, 301 Pine Tree Road, Ithaca, NY, 14850,” including set of revised drawings titled
Proposed Mirabito Redevelopment Project, 301 Pine Tree Road, Ithaca, NY, 14850, Town
of Ithaca, Tompkins County, New York State,” with sheets C-0, C-1, C-2, C-2.1, C-3
through C-14, prepared by Napierala Consulting, dated 05 May, 2023 and most recently
revised 1/14/2025; architectural plans titled “Convenience Center W/Fuel, Mirabito, Ithaca,
NY,” including sheets A-101 through A-116, prepared by Delta Engineers, Architects &
Surveyors, dated 02/06/2025; a subdivision plat titled “Subdivision Map, For Cornell
University Located At, No. 1010 Ellis Hollow Road and No. 301 Pine Tree Road, Town of
PB 2025-02-18 (Fled 2/21) Pg. 13
Ithaca, Tompkins County, New York,” prepared by T.G. Miller, P.C., dated 4/17/2023 and
revised 6/15/2023; and other application materials, and
4. Project plans, and related information, were duly delivered to the Tompkins County
Planning and Sustainability Department per New York State General Municipal Law §§239-
l et seq., and such Department responded in a January 31, 2025, letter from Katherine
Borgella, Tompkins County Commissioner of Planning, pursuant to §§239-l, -m, and -n of
the New York State General Municipal Law, determining that the proposed action will have
no significant county-wide or inter-community impact;
NOW THEREFORE BE IT RESOLVED:
That the Planning Board hereby finds that the Special Permit standards of Article XXIV Section
270-200, Subsections A – H, of the Town of Ithaca Code, have been met, specifically that:
A. The project will be suitable for the property on which it is proposed, considering the property’s
size, location, and physical site characteristics.
The project involves a subdivision and consolidation of adjacent parcels to accommodate the
combined proposed commercial uses, which are uses that already exist separately on each
parcel (or formerly existed, in the case of the Burger King). The properties are located in a
commercial zone, and their physical site characteristics are appropriate for the proposed
project.
B. The proposed structure design and site layout are compatible with the surrounding area.
The proposed structure design is more compatible with the surrounding area than the 1970’s
architecture that dominates the East Hill Plaza. The proposal includes modern architectural
designs that match some of the other nearby commercial uses. The site layout has been
specifically structured to be compatible with the Traditional Neighborhood Development
goals of the Town Comprehensive Plan.
C. Operations in connection with the proposed use do not create any more noise, fumes, vibration,
illumination, or other potential nuisances than the operation of any permitted use in the zone.
The proposed uses will be the same as the existing uses – gas station, convenience store,
and drive-thru restaurant. Operations in connection with the uses will be similar to existing.
All outdoor lighting is required to comply with the Town Outdoor Lighting Law.
D. Community infrastructure and services, such as police, fire and other protective services,
roadways, schools, and water and sewer facilities are currently, or will be, of adequate capacity
to accommodate the proposed use.
All community infrastructure and services are of adequate capacity to accommodate the
use.
E. The proposed use, structure design, and site layout will comply with all the provisions of the
Town Code and with the Town of Ithaca Comprehensive Plan, except where variances are
being considered by the Zoning Board of Appeals.
F. The site layout, with proposed vehicular, bicycle and pedestrian access, traffic circulation, and
parking and loading facilities, is sufficient for the proposed use and is safely designed for
emergency vehicles.
PB 2025-02-18 (Fled 2/21) Pg. 14
The project has been carefully designed for safe vehicular, bicycle, pedestrian access, traffic
circulation, and parking and loading facilities. All accessways have been safely designed for
emergency vehicles.
G. The project includes sufficient landscaping and/or other forms of buffering to protect
surrounding land uses. Existing vegetation is preserved to the extent possible.
There is minimal tree and vegetation loss associated with the project, including removal of
mature Norway Spruce trees, which are on the list of Invasive Plants of the Ithaca New York
Area (2017). The project includes some landscaping. The applicant may be required to
increase the amount of landscaping and the size of proposed trees before consideration of
final site plan approval.
H. To the extent deemed relevant by the Planning Board, the proposed use or structure complies
with all the criteria applicable to site plan review set forth in Chapter 270, Zoning.
AND BE IT FURTHER RESOLVED:
That the Town of Ithaca Planning Board hereby grants Preliminary Site Plan Approval and
Preliminary Subdivision Approval for the proposed Mirabito Redevelopment Project, as shown on
the submitted plans referenced in Whereas #3 above, with the following conditions to be met:
Prior to Final Site Plan/Final Subdivision Approval
a. Submission of a revised set of coordinated site plan, civil, and architectural drawings that
show all the same elements of the proposal (e.g., Site Plan C-3 should show striping across
crosswalk per A-111 rendering; and rendering A-116 should show striped crosswalk across
Ellis Hollow Road),
b. Submission of the following revised plans:
i. Landscaping Plan (Sheet C-7), showing additional landscaping along the Ellis Hollow
Road frontage of the project, with non-invasive, local, deer-resistant trees and shrubs
trees of a larger caliper, where possible),
ii. Layout plan (Sheet C-3) showing the placement of a least one bike rack near the main
entrance to the project,
iii. Detail plan (Sheet C-10) eliminating the chain-link fence and showing a different type
of fencing material around the proposed dumpster enclosure,
c. Revision of the lighting plan to indicate a 3000k maximum LED color temperature for the
proposed canopy lights, light poles, and building lighting, except as otherwise required by
NFPA,
d. Submission of all site details including (but not limited to) exterior furnishings, patio
furnishings, bicycle racks, walls, railings, bollards, and paving materials,
e. Submission of a construction staging plan for the project, along with a truck hauling plan
that shows the proposed truck routes for any materials entering or exiting the project site
pre-construction and during construction,
PB 2025-02-18 (Fled 2/21) Pg. 15
f. Submission for review and approval by the Town Engineering Department, of all the items
related to SWPPP that are noted on the memo written by David O’Shea, Town Engineer,
and Justin McNeal, Civil Engineer, dated February 4, 2025,
g. Submission of proof from the Tompkins County Highway Department that the project
improvements proposed within the county right-of way are acceptable,
h. Submission, for review and approval by the Director of Code Enforcement, of a fire
apparatus access plan, showing the Ithaca Fire Department auto turn path,
i. Submission, for review and approval by the Director of Code Enforcement, of fire flow
calculations with the method(s) utilized to verify compliance with the 2020 NYS Fire Code
Section 507.1,
j. Granting of any necessary variances from the Zoning Board of Appeals,
Prior to Issuance of a Building Permit:
k. Submission, review, execution, and filing of an Operation, Maintenance and Reporting
agreement for the proposed stormwater management facilities, with the Town of Ithaca,
specifying the ownership and maintenance responsibilities for the stormwater system,
including:
i. Submission of an access easement, or other mechanism, to assure Town of Ithaca
access to the stormwater facilities,
ii. Review and approval of the access easement and the Operation, Maintenance, and
Reporting Agreement by the Attorney for the Town and the Town Engineer, and
iii. Town Board authorization to allow the Town Supervisor to sign any necessary
easements and the Stormwater Operation, Maintenance, and Reporting Agreement
associated with the project,
l. Submission for signing by the Planning Board Chair of an original and three dark lined
prints of the approved final subdivision map, revised to state “Pine Tree Road,” instead of
Judd Falls Road,” prior to filing with the Tompkins County Clerk’s Office; and submission
of a copy of the receipt of filing to the Planning Department,
m. Within six months of the final approval, consolidation of Parcels 1-A, 1-B, and 1-C on the
approved subdivision plat, and submission to the Town Planning Department of a copy of
the completed Tompkins County Consolidated Request form,
n. Approval by the Town Board, full execution and filing of a water easement granted from
Cornell University to the Town of Ithaca for the maintenance and access to the water
infrastructure; such easement shall be satisfactory to the Attorney for the Town and the
Town of Ithaca Director of Engineering,
o. Submission of a copy of any required highway work permits from the Tompkins County
Highway Department.
Moved: Liz Bageant Seconded: Sara Reynolds
Vote: Ayes: Cameron, Bageant, Reynolds, Arms, McGurk
PB 2025-02-18 (Fled 2/21) Pg. 16
Item 5. Approval of Minutes
Approval of the December 17, 2024, January 7, 2025, and January 21, 2025, minutes.
Moved: Liz Bageant Second: Caitlin Cameron
Vote: Ayes- Cameron, Bageant, Reynolds, Arms, McGurk
Item 6. Other Business
Report from the Attorney for the Town regarding the conditions necessary to consider a re-vote on a
prior action. Ms. Brock stated that New York case law described when a Planning Board may
reconsider a prior approval and noted that the board cannot be arbitrary and capricious in their
decision to reconsider. She explained the situations where reconsideration would be appropriate:
A straw poll was taken regarding if any Planning Board members felt that any of these conditions
applied to the Wiedmaier Court Verizon Telecommunications Tower project approval. The Board
did not think any of the conditions applied in the case of the Wiedmaier tower. The Board will
therefore not reconsider the approval that was issued.
Staff informed the board of projects for the next couple of meetings. The meeting was adjourned
upon a motion and a second; unanimous.
Submitted by
Monica Moll, Deputy Town Clerk
The Planning Board issued an approval in excess of its legal authority (example: a town Planning
Board approves a subdivision that includes land outside the town)
There has been a material change in circumstances since the approval
New evidence is presented
The application was misleading
From:
To:
Subject:
Sent:
Jill Kellner
Town Of Ithaca Planning
artificial turf at Cornell
3/17/2025 8:38:44 AM
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Dear Town Planning Board Members,
I live at 1321 Ellis Hollow Road and am very concerned that you would allow Cornell
to consider using artificial turf on their fields. It is a threat to us all.
The August 2024 report from the University of Massachusetts Lowell confirms
that PFAS have been detected in all components of artificial turf, including
blades, backing, infill, shock pads, adhesives, and even product packaging. Despite
Cornell University’s claims that its field hockey turf is different because it lacks infill,
this report demonstrates that PFAS contamination is not limited to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO
materials. However, this study, conducted by a respected research center with full
citations and expert analysis, is highly relevant to the town planning board’s review.
Declaring a negative declaration without considering this research is a failure of due
diligence. It is also deeply problematic that Cornell seeks to control the narrative by
discounting high-quality investigative journalism and research from credible
organizations—especially in a rapidly evolving field where new findings emerge
constantly.
Additionally, some artificial turf manufacturers have marketed their products as
PFAS-free,” but testing in this report reveals PFAS were still found in those materials.
This raises serious concerns about the validity of PFAS-free claims and the broader
regulatory loopholes that allow these chemicals to go unreported.
I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their
synthetic turf products is PFAS-free. However, this guarantee does not inspire
confidence for several reasons. First, FieldTurf does not provide total fluorine (TF)
testing, which is critical for detecting hidden PFAS, including polymeric PFAS and
precursors. Second, they do not specify detection limits for their PFAS tests—without
knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals,
ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this
statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free
certification.This raises an important question: What kind of PFAS-free guarantee does
TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning
board must obtain and critically evaluate TenCate’s PFAS-free claims, including their
detection thresholds, test methods, and whether they include total organic fluorine
TOF) and total oxidizable precursors (TOP) testing. Without this information, the
board has not taken the "hard look" required under SEQRA. Given that PFAS have
been found in artificial turf products marketed as "PFAS-free," it is reckless to assume
that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s
guarantee.Additionally, I want to note that these reports have been included in Zero
Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along.
It is disappointing that the town planning board is moving forward with a Negative
Declaration for the EIA despite these submissions, appearing to yield to political
pressure from Cornell University rather than prioritizing scientific integrity and the
protection of our community’s health and environment.Hereby, we have submitted this
evidence for your review, ensuring that the record reflects these critical findings, which
you are choosing to disregard as you move forward with a Negative Declaration.
Sincerely,
Jill Kellner
1321 Ellis Hollow Road
References:
1. Lowell Center for Sustainable Production, University of Massachusetts
Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf:
Academic, Municipal, and Other Testing Efforts. August
2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in-
Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18-
386957.pdf?rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0.
The compilation of PFAS testing from academic, municipal, and independent
studies confirms that PFAS have been detected in all components of artificial
turf, including turf blades, carpet backing, infill, shock pads, adhesives, and
even product packaging. Total fluorine (TF) testing consistently found
fluorine across various samples, with concentrations ranging from 16 to 661
µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated
coatings, or PFAS-based processing aids. Extractable PFAS tests detected
long- and short-chain PFAS in multiple studies, particularly fluorotelomer
alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf
fibers, and PFAS precursors in adhesives and shock pads. Municipal and
nonprofit-led testing further corroborates these findings, with PFAS measured
in stormwater runoff, installation materials, and artificial turf fields marketed
as ‘PFAS-free.’ These results highlight significant gaps in industry claims and
emphasize the need for stricter regulations and improved testing
methodologies to assess the full extent of PFAS contamination in artificial turf
systems.
2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the
Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth,
NH. October 22,
2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas-
statement-fieldturf-1.pdf
A supplier for FieldTurf/Tarkett Sports claims that their artificial turf
filaments/fibers are fluorine-free and do not contain PFAS, including PFOS,
based on manufacturing consistency and compliance with REACH
regulations. However, the declaration lacks total fluorine testing, does not
specify PFAS detection limits, and does not test the full turf system, meaning
polymeric PFAS or precursors could still be present. Additionally, there is no
independent third-party verification, making the PFAS-free claim
scientifically weak and incomplete.
3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A
Zero Waste Ithaca Bibliography. Updated March 16, 2025
https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-
s_4bfbmO26R-Q/edit?usp=sharing
From:
To:
Cc:
Subject:
Sent:
Louise Mygatt
Town Of Ithaca Planning
pbstaff@cityofithaca.org
artificial turf
3/17/2025 12:06:06 PM
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address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town Planning Board Members,
The attached August 2024 report from the University of Massachusetts Lowell
confirms that PFAS have been detected in all components of artificial turf,
including blades, backing, infill, shock pads, adhesives, and even product
packaging. Despite Cornell University’s claims that its field hockey turf is different
because it lacks infill, this report demonstrates that PFAS contamination is not limited
to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO
materials. However, this study, conducted by a respected research center with full
citations and expert analysis, is highly relevant to the town planning board’s review.
Declaring a negative declaration without considering this research is a failure of due
diligence. It is also deeply problematic that Cornell seeks to control the narrative by
discounting high-quality investigative journalism and research from credible
organizations—especially in a rapidly evolving field where new findings emerge
constantly.
Additionally, some artificial turf manufacturers have marketed their products as
PFAS-free,” but testing in this report reveals PFAS were still found in those materials.
This raises serious concerns about the validity of PFAS-free claims and the broader
regulatory loopholes that allow these chemicals to go unreported.
I am also attaching a PDF from FieldTurf, in which they claim that one of their
synthetic turf products is PFAS-free. However, this guarantee does not inspire
confidence for several reasons. First, FieldTurf does not provide total fluorine (TF)
testing, which is critical for detecting hidden PFAS, including polymeric PFAS and
precursors. Second, they do not specify detection limits for their PFAS tests—without
knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals,
ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this
statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free
certification.
This raises an important question: What kind of PFAS-free guarantee does TenCate—
the manufacturer of Cornell’s new field hockey turf—provide? The planning board
must obtain and critically evaluate TenCate’s PFAS-free claims, including their
detection thresholds, test methods, and whether they include total organic fluorine
TOF) and total oxidizable precursors (TOP) testing. Without this information, the
board has not taken the "hard look" required under SEQRA. Given that PFAS
have been found in artificial turf products marketed as "PFAS-free," it is reckless to
assume that Cornell’s turf is truly PFAS-free without independently verifying
TenCate’s guarantee.
Additionally, I want to note that these reports have been included in Zero Waste
Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It
is disappointing that the town planning board is moving forward with a Negative
Declaration for the EIA despite these submissions, appearing to yield to political
pressure from Cornell University rather than prioritizing scientific integrity and the
protection of our community’s health and environment.
Hereby, we have submitted this evidence for your review, ensuring that the record
reflects these critical findings, which you are choosing to disregard as you move
forward with a Negative Declaration.
Sincerely,
Dr. Louise Mygatt
Dear Town Planning Board Members,
The attached August 2024 report from the University of Massachusetts Lowell confirms
that PFAS have been detected in all components of artificial turf, including blades,
backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell
University’s claims that its field hockey turf is different because it lacks infill, this report
demonstrates that PFAS contamination is not limited to infill alone.
However, this study, conducted by a respected research center with full citations and expert
analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration
without considering this research is a failure of due diligence. It is also deeply problematic that
Cornell seeks to control the narrative by discounting high-quality investigative journalism and
research from credible organizations—especially in a rapidly evolving field where new findings
emerge constantly.
I am so grateful for to see the studies that ZWI have provided our community from their
legitimate, scholarly research that exhibits how horrifying this turf project is.
CAN YOU LIFT YOUR HEAD OUT OF CORNELL’S DECEPTION AND SEE IT?
WE WILL NOT STAND FOR THIS!!!!!
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. It’s
absolutely beyond the pale that this institution that proclaims itself as a leader in scientific
research would represent themselves in such a horrifying manner.
TRULY.
Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but
testing in this report reveals PFAS were still found in those materials. This raises serious
concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow
these chemicals to go unreported.
I appeal to each of you on this board who have shown your interest and dedication to
making Ithaca healthy and safe. I know who you are, and I want you to use your voice to
REQUEST a deeper study goes into this.
DO NOT let Cornell bully you!
I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic
turf products is PFAS-free. However, this guarantee does not inspire confidence for several
reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting
hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection
limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess
the credibility of their claim. Third, their methodology likely focuses only on a small subset of
PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this statement is just
a self-reported manufacturer claim rather than a rigorous PFAS-free certification.
This raises an important question: What kind of PFAS-free guarantee does TenCate—the
manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and
critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test
methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors
TOP) testing. Without this information, the board has not taken the "hard look" required
under SEQRA. Given that PFAS have been found in artificial turf products marketed as
PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently
verifying TenCate’s guarantee.
I also want to note that these reports have been included in Zero Waste Ithaca's bibliography
under the "Independent Testing of PFAS" section all along. It is disappointing that the town
planning board is moving forward with a Negative Declaration for the EIA despite these
submissions, appearing to yield to political pressure from Cornell University rather than
prioritizing scientific integrity and the protection of our community’s health and environment.
And one last piece: Cornell also plans to do “independent” testing in addition to the
manufacturer’s “PFAS-free” guarantee, but the testing will be done before it leaves the
manufacturer, with zero specifications about testing method, threshold, etc - really confidence
inspiring, according to page 10 of Supplemental Materials Submission dated January 31, 2025.
Hereby, we have submitted this evidence for your review, ensuring that the record reflects these
critical findings, which you are choosing to disregard as you move forward with a Negative
Declaration.
Do what’s right, people. THIS REQUIRES A COMPLETE ASSESSMENT!
Sincerely,
Caroline Ashurst
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1
Per-and Poly-fluoroalkyl Substances
PFAS)in Artificial Turf:Academic,
municipal,and other testing efforts
August 2024
A number of organizations have conducted PFAS testing in artificial turf materials. These include academic
studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or
vendors, sometimes with the assistance of consulting firms. This document provides a compilation of
results that have been reported from many of these testing efforts.
This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in
artificial turf, and for a discussion of key considerations related to test methods. For another recent
summary of test results, see the New Jersey Department of Environmental Protection’s Technical
Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s
report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3
Test results are summarized below for academic studies; regional and municipal studies; nonprofits,
community organizations, and journalists; and manufacturers. Testing has been carried out using a variety
of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or
precision of the methods or results.
Academic studies
Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and
expanded the information available on the presence of PFAS in these materials. Results from these studies
are summarized in Table 1.
Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and
targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm,
Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene
rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork,
bark, and coconut).
TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic
material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted
analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently.
The authors explain that “collectively, these results point toward polymeric organofluorine (e.g.,
fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2
Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be
landfilled or incinerated.
Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method
to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made
with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more
harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography-
mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb
rubber infill.
Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf
blades to determine the presence of PFAS.6
For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to
raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic
product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the
manufacturing process.
Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below
detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that
much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of
fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing
literature.
Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem
mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of
PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of
eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The
median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS
concentrations was 41.7 ng/g (ppb).
Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial
turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial
turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong
degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing
aids." This information further supports the possibility that fluorinated polymers were added to the resin.
A TOP assay was performed on four samples including artificial turf and product packaging. Because this
testing included both artificial turf and other plastic products, this information is relevant primarily for
refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did
not have significant changes in concentration after oxidation. This was likely because those samples did not
contain substantial quantities of the precursor PFAS that break down into the degradation products that
were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and
showed a higher concentration of degradation products after oxidation. This suggested that the sample
contained higher quantities of the precursors that were measured in the TOP assay.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3
A conclusion of this study was that “these results suggest that much of the total fluorine signals measured
in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what
might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that
targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various
plastic products.” In other words, this study further supports the importance of carefully choosing test
methods that can accurately characterize PFAS content in artificial turf materials.
Table 1. Summary of PFAS testing from academic studies.
Source Summary
Lauria et al.
2022)4
Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of
artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing,
carpet blades, and infill.
TOTAL FLUORINE
TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 g of F/g in
backing, filling, and blades, respectively).”
TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic
material infills.
EXTRACTABLE ORGANIC FLUORINE
Backing: range from <LOD - 145 ng of F/g (ppb)
Infill: range from <LOD - 179 ng of F/g (ppb)
Blades: range from <LOD - 192 ng of F/g (ppb)
TARGETED ANALYSIS
Results were reported as the sum of fluorine in a sample.
Backing: <LOD - 0.63 ng of F/g (ppb)
Infill: <LOD - 0.15 ng of F/g (ppb)
Blades: “absent”
Zuccaro et al.
2023)5
A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH)
in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and
analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM).
FLUOROTELOMER ALCOHOLS PILOT TEST:
8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at
concentrations of 1.0 and 0.71 ng/L [ppm], respectively. This translates to 300ng 8:2 FTOH/g
artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH
were not found to be present in detectable levels.”
Whitehead
2023)
dissertation)6
Analyzed PFAS in 27 samples of artificial turf blades using several methods.
TOTAL FLUORINE
Measured using particle-induced gamma ray emission (PIGE) spectroscopy.
TF ranged from <LOD to 2.94 µg F/cm2.
TARGETED ANALYSIS
Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC-
MS/MS)
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4
PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples
was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb).
ORGANIC FLUORINE
Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results
were “indicative of the presence of organic fluorine in these samples, with a strong degree of
similarity between spectra collected from samples to that of raw fluorinated polymer
processing aids."
TOP ASSAY (four samples only)
T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t
have significant changes in their sum of PFAS concentrations. The sample which had the
highest sum of PFAS concentrations before TOP assay showed a more significant increase in
measured concentrations.”
Results suggest that “the concentrations of fluorine measured through PIGE are likely
indicative of PFAS which does not undergo transformation” into the compounds measured in
the TOP assay.
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
Regional and Municipal Studies
The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and
two adhesives used during the installation of an artificial turf field.7 The analyses included targeted
analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic
precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both
organic and inorganic analytes present in liquids, soils, and wastes."8
PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in
the carpet, and lower quantities in other materials. Additional results are summarized in Table 2.
The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed
as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new
artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock
pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham
Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total
fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer
processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial
grass.”9
The City of Portsmouth later initiated further testing with help from a consulting group. This effort included
a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis.
The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed
presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill,
the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are
summarized in Table 2.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5
Table 2. Summary of PFAS testing led by regional institutions and municipalities.
Source Summary
Martha’s
Vineyard, MA
2020).7
Laboratory results
interpreted by
consultants at
Tetra Tech
Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives
used during field construction.
TARGETED ANALYSIS
Total PFAS by isotope dilution method”
Detected certain PFAS at concentrations above the method detection limit (MDL) but
below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb);
Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb).
Synthetic Precipitation Leaching Procedure
Select PFAS compounds were detected in the SPLP analysis that were not detected in the
total PFAS analysis.”
The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L),
shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the
adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total
PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are
equivalent to ppt.)
The detection of PFAS compounds in the samples of the synthetic turf components via
SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain
PFAS compounds that were not extractable via the analytical method utilized for total PFAS
analysis (isotope dilution method), but were extractable by the more rigorous SPLP
extraction process.”
TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY
PFAS were not detected during the pre-oxidation measurements.
The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all
sample materials at concentrations above the method detection limit but below the
reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g.
Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill]
at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)”
Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at
a concentration of 6.08 ng/g.” This concentration was above the method detection limit
but below the reporting limit, yielding an estimated value.
TOTAL ORGANIC FLUORINE
Total organic fluorine was detected in the [carpet] at a calculated concentration of 70
parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second
adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting
that the total fluorine detected in these samples likely represents primarily organic
fluorine. However, because the RL in some cases is close to the detected concentration of
total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine
was not detected in the sample of the [wood infill] above the RL of 10 ppm.”
Additional note from consultant report
The consultant noted that there were difficulties in the laboratory’s approach. “The detection
limits achieved by the laboratory were elevated because of the limited sample weight utilized
during extraction and the dilutions required by the low density sample matrix.”
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6
Portsmouth, NH
2021) initial
community
testing9
The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center,
initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad.
An independent laboratory measured total fluorine in these materials.
TOTAL FLUORINE
Carpet: TF: 83- 119 ppm
Backing: TF: 16 ppm
Shock pad: TF: 61 ppm
Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total
fluorine measurements are typical for plastics that have been manufactured with PFAS-
based polymer processing aids – which will leave residues of these PFAS at the part-per-
million level on the artificial grass.” 9
Portsmouth, NH
2022) testing
initiated by City of
Portsmouth.
Laboratory results
interpreted by
consultants at
TRC10
Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock
pad. Results summarized here show presence of substances only. See full report for
concentrations.
TARGETED TESTING AND TOP ASSAY
PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70
individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope
dilution liquid chromatography/dual mass spectrometry” in samples of material. This method
is considered a targeted test method. Samples were also oxidized and measured for PFAS
precursors.
Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples.
Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was
also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].”
Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was
also detected in a blank sample). Six PFAS were detected in samples after oxidation.
Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA
was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a
concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation.
NON-TARGETED ANALYSIS
Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were
performed on each sample to determine if “other” PFAS were present that were not included
in the analysis of the 70 individual PFAS.”
Results were “qualitative estimations of presumptive positives.” Several additional
chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl)
carbonate, was tentatively identified in the carpet sample. The other chemicals were
reported as “unknown.”
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking
water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7
Nonprofits, Community Organizations, and Journalists
A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial
turf. Below are some examples.
Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet
and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11
The organizations tested backing of both new turf and older, discarded turf. They also tested a number of
samples of artificial grass blades (carpet fibers).
They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA
has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In
many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS.
They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is
a long-chain PFAS that is no longer manufactured in the US due to concerns about health and
environmental effects.
They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of
fluorine that suggest the presence of PFAS.11
Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted
samples of new and older turf to commercial and research laboratories for various types of PFAS analyses.
Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected
from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS-
free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after
the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS
measured after installation were higher than the levels measured before installation. Three other PFAS
were also detected in the post-installation stormwater samples (see Table 3).
Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the
Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre
Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12
ppt) and PFOS (5.5 ppt).
PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8
Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists.
Source Summary
NONPROFIT AND COMMUNITY ORGANIZATIONS
Testing reported in
The Intercept
2019).11 Results
summarized by New
Jersey Department of
Environmental
Protection.2
Targeted and total fluorine testing conducted on new turf carpet samples; targeted
testing conducted on used sample.
TARGETED ANALYSIS
New turf carpet sample: 6:2 FTSA: 300 ppt
Used turf carpet sample: PFOS: 190 ppt
TOTAL FLUORINE ANALYSIS
New turf carpet blades: 44-255 ppm
Woodbridge, CT
2021)12
Samples of stormwater runoff were collected before and after the installation of an
artificial turf field from a swale located near the artificial turf field installation site.
Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS.
TARGETED ANALYSIS of runoff
Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt)
After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L
ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt)
Preliminary dermal
exposure tests by
Public Employees for
Environmental
Responsibility
PEER)13
Used skin wipes to measure PFAS on four individuals before and after play. Results
showed differences in pre- and post-play PFAS levels for artificial turf and grass.
Center for
Environmental
Health (CEH)14,15
CEH tested samples of artificial grass used for residential applications. PFOS was
detected during testing. Based on the levels detected, CEH sent California Proposition
65 notices of violation to relevant parties.
JOURNALIST
Philadelphia Inquirer
2023)16
The Philadelphia Inquirer purchased samples of artificial turf carpet used by
Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and
University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS.
TARGETED ANALYSIS
Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt).
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods
or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or
ppt in parentheses for ease of interpretation. <LOD = below level of detection.
Manufacturers
Determining which chemicals are present in a product can be challenging because chemical contents are
frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9
manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of
two manufacturers that have provided test data.
As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and
PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in
determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the
two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was
detected above this threshold.
Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The
manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts
consulted by the journalists suggested that the laboratory test results had limited value, in part because of
high detection limits.18
In some cases, targeted tests have been used to inform PFAS-free statements. For example, one
manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at
100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17
In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term
PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100
ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile
products.21)
Table 4. Examples of PFAS testing led by manufacturers.
Source Summary
Artificial turf
manufacturer example
1 (2023)17
The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of
PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting
solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The
lowest calibrated detection is at 100 parts per trillion.”
TARGETED ANALYSIS OF PFOA AND PFOS
PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect
concentrations below 100 ppt.
Artificial turf
manufacturer example
2 (2022)22
Results summarized by
The Philadelphia Inquirer
2024)18
The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI
Laboratories Inc. for targeted PFAS testing.
TARGETED ANALYSIS
The laboratory’s summary of results stated that “all extractable PFAS compounds
were non-detect at a level of 2-4 ug/kg (ppb).”22
Experts consulted by The Philadelphia Inquirer expressed concerns about the testing
methods and the high detection limits used. They noted that lower detection limits
and a total organic fluorine test would have yielded results that are more
informative.18
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10
Acknowledgments
This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable
Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger-
Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather
Whitehead, PhD.
This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same
authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl
Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra
Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection,
State of New Jersey. Research for this report was supported by The Heinz Endowments.
The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative
strategies for communities and workplaces to adopt safer and sustainable practices and products to protect
human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students
at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions,
and government agencies to build healthy work environments, thriving communities, and viable businesses
that support a more sustainable world.
References
1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18-
385224.pdf (July 2024).
2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in
artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023).
3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory
Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023).
4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from
Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672.
5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols
FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber
infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280.
6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant
to human health and the environment (dissertation),
https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A
nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023).
7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report,
https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL
February 2021).
8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure,
https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024).
9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021,
https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new-
synthetic-turf-field/ (2021).
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11
10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf,
https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf
2022).
11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019,
https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October
2019).
12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021.,
https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021).
13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin,
https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024).
14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act:
Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document.,
https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024).
15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024.,
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024).
16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed.
Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas-
forever-chemicals-cancer-20230307.html (2023).
17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp-
content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024).
18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The
Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-
turf-field-murphy-recreation-20240223.html (23 February 2024).
19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and-
artificial-grass/ (2023, accessed 5 June 2024).
20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/.
21. State of California. CA Health & Safety Code § 108945,
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha
pter=12.5.&article= (2022).
22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022,
https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022).
From:
To:
Cc:
Subject:
Attachments:
Sent:
AKWilson
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Comments on Field Hockey Turf on Game Farm Road Site
PFAS detected in all components of Artificial Turf - Academic Municipal
Other Tests Aug 2024_tcm18-386957-1.pdf;met-pfas-statement-
fieldturf-1 (copy).pdf;
3/17/2025 5:30:28 PM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town Planning Board Members,
We do not support the installation of fields made of synthetic turf on the Game Farm Rd site in
the town of Ithaca. Such fields pose unacceptable risks and hazards to human health and the
wider environment and are not appropriate to our community.
The attached August 2024 report from the University of Massachusetts Lowell confirms that
PFAS have been detected in all components of artificial turf, including blades, backing, infill,
shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its
field hockey turf is different because it lacks infill, this report demonstrates that PFAS
contamination is not limited to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” "NGO reports."
However, this study, conducted by a respected research center with full citations and expert
analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration
without considering this research is a failure of due diligence. It is also deeply problematic that
Cornell seeks to shape the narrative by discounting high-quality investigative journalism and
research from credible organizations—especially in a rapidly evolving field where new findings
emerge constantly on PFAS and microplastics.
Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but
testing in this report reveals PFAS were still found in those materials. This raises serious
concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow
these chemicals to go unreported.
We are also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf
products is PFAS-free, which turned out to be false as reported in the UMass Lowell report. This
guarantee by the manufacturer does not inspire confidence for several reasons. First, FieldTurf
does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including
polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests
without knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring
precursors and polymeric forms that may degrade over time into more hazardous compounds.
Lastly, without third-party, independent verification, this statement is just a self-reported
manufacturer claim rather than a rigorous PFAS-free certification.
This raises an important question: What kind of PFAS-free guarantee does TenCate—the
manufacturer of Cornell’s new field hockey turf—provide? The planning board must first obtain
and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test
methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors
TOP) testing. Without this information, the board has not taken the "hard look" required under
SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it
is reckless to issue Negative Declaration and assume that Cornell’s turf is truly PFAS-free without
independently verifying TenCate’s guarantee.
Cornell claims that it will carry out “independent” testing in addition to the
manufacturer’s “PFAS-free guarantee”, however the testing will be done before the
product leaves the manufacturer, and they provide no specifications about methods,
thresholds or what will be tested for: eg. TF and/or which specific PFAS.
Sincerely,
Allison Wilson, Ph.D. and Jonathan Lathan, Ph.D.
Bioscience Resource Project
Reference:
Lowell
Center for Sustainable Production, University of Massachusetts Lowell. Per- and Polyfluoroalkyl
Substances
PFAS) in Artificial Turf: Academic, Municipal, and Other Testing Efforts. August 2024.
https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in-Artificial-Turf-Academic-
Municipal-Other-Tests-Aug-2024_tcm18-386957.pdf?
rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0.
The compilation of PFAS testing from academic, municipal, and independent studies confirms
that PFAS
have been detected in all components of artificial turf, including turf blades, carpet
backing, infill, shock pads, adhesives, and even product packaging. Total fluorine (TF)
testing consistently
found fluorine across various samples, with concentrations ranging from 16 to 661 µg/g (ppm),
suggesting the widespread use of polymeric PFAS, fluorinated coatings, or PFAS-based
processing aids. Extractable PFAS tests detected long- and short-chain PFAS in
multiple studies, particularly fluorotelomer alcohols (FTOHs) in crumb rubber infill,
perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS precursors in adhesives and
shock pads. Municipal and nonprofit-led testing further corroborates these findings, with
PFAS measured in stormwater runoff, installation materials, and artificial turf fields
marketed as ‘PFAS-free.’ These results highlight significant gaps in industry claims and
emphasize
the need for stricter regulations and improved testing methodologies to assess the full extent of
PFAS contamination in artificial turf systems.
Allison Wilson, PhD
Science Director
The Bioscience Resource Project
phone: 1 (607) 319 0279
a.wilson@bioscienceresource.org
https://www.independentsciencenews.org/
and
https://bioscienceresource.org/
and
https://www.poisonpapers.org/
Please sign on to our mailing list: https://www.independentsciencenews.org/subscribe/
Good with Science"
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1
Per-and Poly-fluoroalkyl Substances
PFAS)in Artificial Turf:Academic,
municipal,and other testing efforts
August 2024
A number of organizations have conducted PFAS testing in artificial turf materials. These include academic
studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or
vendors, sometimes with the assistance of consulting firms. This document provides a compilation of
results that have been reported from many of these testing efforts.
This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in
artificial turf, and for a discussion of key considerations related to test methods. For another recent
summary of test results, see the New Jersey Department of Environmental Protection’s Technical
Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s
report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3
Test results are summarized below for academic studies; regional and municipal studies; nonprofits,
community organizations, and journalists; and manufacturers. Testing has been carried out using a variety
of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or
precision of the methods or results.
Academic studies
Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and
expanded the information available on the presence of PFAS in these materials. Results from these studies
are summarized in Table 1.
Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and
targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm,
Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene
rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork,
bark, and coconut).
TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic
material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted
analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently.
The authors explain that “collectively, these results point toward polymeric organofluorine (e.g.,
fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2
Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be
landfilled or incinerated.
Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method
to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made
with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more
harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography-
mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb
rubber infill.
Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf
blades to determine the presence of PFAS.6
For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to
raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic
product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the
manufacturing process.
Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below
detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that
much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of
fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing
literature.
Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem
mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of
PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of
eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The
median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS
concentrations was 41.7 ng/g (ppb).
Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial
turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial
turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong
degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing
aids." This information further supports the possibility that fluorinated polymers were added to the resin.
A TOP assay was performed on four samples including artificial turf and product packaging. Because this
testing included both artificial turf and other plastic products, this information is relevant primarily for
refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did
not have significant changes in concentration after oxidation. This was likely because those samples did not
contain substantial quantities of the precursor PFAS that break down into the degradation products that
were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and
showed a higher concentration of degradation products after oxidation. This suggested that the sample
contained higher quantities of the precursors that were measured in the TOP assay.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3
A conclusion of this study was that “these results suggest that much of the total fluorine signals measured
in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what
might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that
targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various
plastic products.” In other words, this study further supports the importance of carefully choosing test
methods that can accurately characterize PFAS content in artificial turf materials.
Table 1. Summary of PFAS testing from academic studies.
Source Summary
Lauria et al.
2022)4
Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of
artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing,
carpet blades, and infill.
TOTAL FLUORINE
TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 g of F/g in
backing, filling, and blades, respectively).”
TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic
material infills.
EXTRACTABLE ORGANIC FLUORINE
Backing: range from <LOD - 145 ng of F/g (ppb)
Infill: range from <LOD - 179 ng of F/g (ppb)
Blades: range from <LOD - 192 ng of F/g (ppb)
TARGETED ANALYSIS
Results were reported as the sum of fluorine in a sample.
Backing: <LOD - 0.63 ng of F/g (ppb)
Infill: <LOD - 0.15 ng of F/g (ppb)
Blades: “absent”
Zuccaro et al.
2023)5
A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH)
in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and
analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM).
FLUOROTELOMER ALCOHOLS PILOT TEST:
8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at
concentrations of 1.0 and 0.71 ng/L [ppm], respectively. This translates to 300ng 8:2 FTOH/g
artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH
were not found to be present in detectable levels.”
Whitehead
2023)
dissertation)6
Analyzed PFAS in 27 samples of artificial turf blades using several methods.
TOTAL FLUORINE
Measured using particle-induced gamma ray emission (PIGE) spectroscopy.
TF ranged from <LOD to 2.94 µg F/cm2.
TARGETED ANALYSIS
Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC-
MS/MS)
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4
PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples
was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb).
ORGANIC FLUORINE
Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results
were “indicative of the presence of organic fluorine in these samples, with a strong degree of
similarity between spectra collected from samples to that of raw fluorinated polymer
processing aids."
TOP ASSAY (four samples only)
T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t
have significant changes in their sum of PFAS concentrations. The sample which had the
highest sum of PFAS concentrations before TOP assay showed a more significant increase in
measured concentrations.”
Results suggest that “the concentrations of fluorine measured through PIGE are likely
indicative of PFAS which does not undergo transformation” into the compounds measured in
the TOP assay.
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
Regional and Municipal Studies
The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and
two adhesives used during the installation of an artificial turf field.7 The analyses included targeted
analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic
precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both
organic and inorganic analytes present in liquids, soils, and wastes."8
PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in
the carpet, and lower quantities in other materials. Additional results are summarized in Table 2.
The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed
as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new
artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock
pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham
Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total
fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer
processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial
grass.”9
The City of Portsmouth later initiated further testing with help from a consulting group. This effort included
a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis.
The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed
presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill,
the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are
summarized in Table 2.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5
Table 2. Summary of PFAS testing led by regional institutions and municipalities.
Source Summary
Martha’s
Vineyard, MA
2020).7
Laboratory results
interpreted by
consultants at
Tetra Tech
Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives
used during field construction.
TARGETED ANALYSIS
Total PFAS by isotope dilution method”
Detected certain PFAS at concentrations above the method detection limit (MDL) but
below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb);
Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb).
Synthetic Precipitation Leaching Procedure
Select PFAS compounds were detected in the SPLP analysis that were not detected in the
total PFAS analysis.”
The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L),
shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the
adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total
PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are
equivalent to ppt.)
The detection of PFAS compounds in the samples of the synthetic turf components via
SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain
PFAS compounds that were not extractable via the analytical method utilized for total PFAS
analysis (isotope dilution method), but were extractable by the more rigorous SPLP
extraction process.”
TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY
PFAS were not detected during the pre-oxidation measurements.
The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all
sample materials at concentrations above the method detection limit but below the
reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g.
Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill]
at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)”
Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at
a concentration of 6.08 ng/g.” This concentration was above the method detection limit
but below the reporting limit, yielding an estimated value.
TOTAL ORGANIC FLUORINE
Total organic fluorine was detected in the [carpet] at a calculated concentration of 70
parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second
adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting
that the total fluorine detected in these samples likely represents primarily organic
fluorine. However, because the RL in some cases is close to the detected concentration of
total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine
was not detected in the sample of the [wood infill] above the RL of 10 ppm.”
Additional note from consultant report
The consultant noted that there were difficulties in the laboratory’s approach. “The detection
limits achieved by the laboratory were elevated because of the limited sample weight utilized
during extraction and the dilutions required by the low density sample matrix.”
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6
Portsmouth, NH
2021) initial
community
testing9
The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center,
initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad.
An independent laboratory measured total fluorine in these materials.
TOTAL FLUORINE
Carpet: TF: 83- 119 ppm
Backing: TF: 16 ppm
Shock pad: TF: 61 ppm
Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total
fluorine measurements are typical for plastics that have been manufactured with PFAS-
based polymer processing aids – which will leave residues of these PFAS at the part-per-
million level on the artificial grass.” 9
Portsmouth, NH
2022) testing
initiated by City of
Portsmouth.
Laboratory results
interpreted by
consultants at
TRC10
Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock
pad. Results summarized here show presence of substances only. See full report for
concentrations.
TARGETED TESTING AND TOP ASSAY
PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70
individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope
dilution liquid chromatography/dual mass spectrometry” in samples of material. This method
is considered a targeted test method. Samples were also oxidized and measured for PFAS
precursors.
Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples.
Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was
also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].”
Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was
also detected in a blank sample). Six PFAS were detected in samples after oxidation.
Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA
was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a
concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation.
NON-TARGETED ANALYSIS
Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were
performed on each sample to determine if “other” PFAS were present that were not included
in the analysis of the 70 individual PFAS.”
Results were “qualitative estimations of presumptive positives.” Several additional
chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl)
carbonate, was tentatively identified in the carpet sample. The other chemicals were
reported as “unknown.”
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking
water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7
Nonprofits, Community Organizations, and Journalists
A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial
turf. Below are some examples.
Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet
and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11
The organizations tested backing of both new turf and older, discarded turf. They also tested a number of
samples of artificial grass blades (carpet fibers).
They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA
has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In
many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS.
They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is
a long-chain PFAS that is no longer manufactured in the US due to concerns about health and
environmental effects.
They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of
fluorine that suggest the presence of PFAS.11
Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted
samples of new and older turf to commercial and research laboratories for various types of PFAS analyses.
Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected
from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS-
free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after
the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS
measured after installation were higher than the levels measured before installation. Three other PFAS
were also detected in the post-installation stormwater samples (see Table 3).
Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the
Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre
Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12
ppt) and PFOS (5.5 ppt).
PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8
Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists.
Source Summary
NONPROFIT AND COMMUNITY ORGANIZATIONS
Testing reported in
The Intercept
2019).11 Results
summarized by New
Jersey Department of
Environmental
Protection.2
Targeted and total fluorine testing conducted on new turf carpet samples; targeted
testing conducted on used sample.
TARGETED ANALYSIS
New turf carpet sample: 6:2 FTSA: 300 ppt
Used turf carpet sample: PFOS: 190 ppt
TOTAL FLUORINE ANALYSIS
New turf carpet blades: 44-255 ppm
Woodbridge, CT
2021)12
Samples of stormwater runoff were collected before and after the installation of an
artificial turf field from a swale located near the artificial turf field installation site.
Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS.
TARGETED ANALYSIS of runoff
Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt)
After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L
ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt)
Preliminary dermal
exposure tests by
Public Employees for
Environmental
Responsibility
PEER)13
Used skin wipes to measure PFAS on four individuals before and after play. Results
showed differences in pre- and post-play PFAS levels for artificial turf and grass.
Center for
Environmental
Health (CEH)14,15
CEH tested samples of artificial grass used for residential applications. PFOS was
detected during testing. Based on the levels detected, CEH sent California Proposition
65 notices of violation to relevant parties.
JOURNALIST
Philadelphia Inquirer
2023)16
The Philadelphia Inquirer purchased samples of artificial turf carpet used by
Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and
University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS.
TARGETED ANALYSIS
Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt).
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods
or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or
ppt in parentheses for ease of interpretation. <LOD = below level of detection.
Manufacturers
Determining which chemicals are present in a product can be challenging because chemical contents are
frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9
manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of
two manufacturers that have provided test data.
As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and
PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in
determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the
two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was
detected above this threshold.
Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The
manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts
consulted by the journalists suggested that the laboratory test results had limited value, in part because of
high detection limits.18
In some cases, targeted tests have been used to inform PFAS-free statements. For example, one
manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at
100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17
In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term
PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100
ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile
products.21)
Table 4. Examples of PFAS testing led by manufacturers.
Source Summary
Artificial turf
manufacturer example
1 (2023)17
The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of
PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting
solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The
lowest calibrated detection is at 100 parts per trillion.”
TARGETED ANALYSIS OF PFOA AND PFOS
PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect
concentrations below 100 ppt.
Artificial turf
manufacturer example
2 (2022)22
Results summarized by
The Philadelphia Inquirer
2024)18
The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI
Laboratories Inc. for targeted PFAS testing.
TARGETED ANALYSIS
The laboratory’s summary of results stated that “all extractable PFAS compounds
were non-detect at a level of 2-4 ug/kg (ppb).”22
Experts consulted by The Philadelphia Inquirer expressed concerns about the testing
methods and the high detection limits used. They noted that lower detection limits
and a total organic fluorine test would have yielded results that are more
informative.18
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10
Acknowledgments
This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable
Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger-
Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather
Whitehead, PhD.
This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same
authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl
Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra
Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection,
State of New Jersey. Research for this report was supported by The Heinz Endowments.
The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative
strategies for communities and workplaces to adopt safer and sustainable practices and products to protect
human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students
at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions,
and government agencies to build healthy work environments, thriving communities, and viable businesses
that support a more sustainable world.
References
1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18-
385224.pdf (July 2024).
2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in
artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023).
3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory
Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023).
4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from
Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672.
5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols
FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber
infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280.
6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant
to human health and the environment (dissertation),
https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A
nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023).
7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report,
https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL
February 2021).
8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure,
https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024).
9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021,
https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new-
synthetic-turf-field/ (2021).
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11
10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf,
https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf
2022).
11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019,
https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October
2019).
12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021.,
https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021).
13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin,
https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024).
14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act:
Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document.,
https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024).
15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024.,
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024).
16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed.
Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas-
forever-chemicals-cancer-20230307.html (2023).
17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp-
content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024).
18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The
Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-
turf-field-murphy-recreation-20240223.html (23 February 2024).
19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and-
artificial-grass/ (2023, accessed 5 June 2024).
20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/.
21. State of California. CA Health & Safety Code § 108945,
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha
pter=12.5.&article= (2022).
22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022,
https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022).
From:
To:
Subject:
Attachments:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning; pbstaff@cityofithaca.org;
Correction of Record: Synthetic Turf Fiber Loss & Cornell’s Expansion
Plan
DTSC 2024 PFAS and Chemical Classes of Concern in Synthetic
Turf.pdf;Woelke D March 4 Cornell 4 Mar 2025-2.pdf;
3/18/2025 1:15:55 AM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town of Ithaca Planning Board Members,
I am submitting the attached documents prepared by Dianne Woelke for California’s
Department of Toxic Substances Control (DTSC). She represents Safe Healthy
Playing Fields, a national nonprofit advocating for safer playing surfaces.
Cornell University has raised concerns regarding one of her earlier submissions from
June for the Meinig Fieldhouse project, specifically stating that her comments about
toxic chemicals contained “no specific citations provided” (Agenda Packet, March 4,
2025, p. 171).
To address this, I have attached her formal comment submitted to DTSC in
September 2024, which includes detailed references to the chemicals listed.
Additionally, I would like to clarify that some criticisms of her submission are
unwarranted. For example, the claim that her concerns about crumb rubber and infill
are “irrelevant” to the Game Farm Road field fails to acknowledge that her original
letter was written specifically for the two synthetic turf fields in and adjacent to the
Meinig Fieldhouse, which do contain infill. Furthermore, she has since submitted a
separate public comment on the Game Farm Road site, which I will also resubmit
for the Planning Board’s review. Notably, page 2 of that comment highlights the loss of
turf fibers and the heightened microplastic pollution risks associated with field
hockey turf blades.
I would like to emphasize one critical finding from her submission regarding synthetic
turf fiber loss and microplastic pollution:
A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its
blades annually. This estimate is ten times lower than a previous Danish
study (0.8 kg/m²). This equates to 2,000 to 3,000 pounds of microplastic
blade loss per year per field. Newer playing fields that do not require infill
poured on top of the synthetic carpet are more densely woven, may have
double backing, and have the potential for significantly greater
microplastic blade and carpet backing loss to the environment.
These findings are particularly relevant to the Game Farm Road field, as it does not
contain infill but may pose even greater microplastic contamination risks due to its
design.
Please review the attached materials.
Best Regards,
Yayoi Koizumi
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
30 September 2024
To: Dr. Meredith Williams
From: Safe Healthy Playing Fields, Inc.
Subj:Candidate Chemicals in Artificial Turf
Dear Dr. Williams:
Thank you for the opportunity to submit these comments on behalf of Safe Healthy Playing
Fields, Inc. (SHPFI).
SHPFI is an all-volunteer 501-c-3 non-profit organization. We are committed to educating
communities, policymakers and elected officials about the health, safety and financial realities of
plastic fields versus grass fields and other synthetic surfaces for their parks and schools. Our
constituency ranges from concerned individuals to community and civic organizations, legal,
healthcare and science professionals, municipal leaders and state legislators.
Toxic and carcinogenic chemicals need to be banned from all consumer products.The plastics
industry continues to impose risks to human and environmental health while developing more
variations of the same class of chemicals, registering untested or inadequately tested chemicals
and products and unleashing them on the unsuspecting public.1,2 We must stop reinventing the
wheel for every plastic product and act decisively- public and environmental health and safety
demand it more now than perhaps ever before.
As a major contributor to the triple threat of the climate crisis3, biodiversity loss4 and the tsunami
of plastic waste5 that has enveloped the earth, it is imperative CA DTSC/SCP take rapid and
decisive action to protect both human and environmental health from this wholly unnecessary
toxic plastic product.
Failure to take timely and decisive action on toxic chemicals has wrought significant burden
globally.Synthetic turf is made of mixed plastics.There are over 16,000 known chemicals
found in plastics. Of the known chemicals, 4,200 are considered “highly hazardous” to human
and environmental health. Of these 4,200 chemicals, only 980 have been regulated by any
global agency and less than one percent can be considered non-hazardous.6 Per- and
polyfluoroalkyl substances (PFAS) are but one of the 15 categories of chemicals of concern in
plastics.
These chemicals add disease burden and health care costs. In the United States (US), for
2018, the attributable cost of plastics to disease and health care related costs was $249 billion;
for PFAS alone, it was $22.4 billion.7 The societal cost globally is estimated at $16 trillion USD
annually for PFAS clean ups and health care for impacted individuals.8
Whether used indoors or out, all fossil fuel based petrochemical plastic grass carpet products
pose unacceptable health risks. So called bio-based plastics do not provide additional
benefit.9,10
Used both indoors and out, synthetic grass carpet is found in commercial and residential
applications. They are installed in childcare centers, gyms, spas, parks, yards, indoor athletic
fields and more. Children and adults play on these surfaces, sometimes on a daily basis, while
sports teams are exposed to these plastic carpets often for 2-3 hours/day, 3-6 days/week. The
highly toxic mix of chemicals of concern present all of the same toxicological traits and adverse
impacts to sub populations that conventional indoor carpets present. Indoor use has a higher
risk for inhalation related injury and long term health consequences due to less ventilation in an
enclosed space.11,12 Whether indoors or out, Infants and young children bear a larger burden of
risk to PFAS and other chemicals in these plastic carpets by virtue of their height and size
relative to older children and adults.
This fossil fuel based petrochemical plastic product poses a threat to human and environmental
health from cradle to grave.Environmental and Social Justice 13 (EJ/SJ) communities are
impacted by synthetic turf. From fracking14 of oil to petrochemical refining15 to manufacturing of
plastic resin pellets in ethane cracker plants,16 to manufacturing of plastic grass carpets and
underlayment pads, to the illegal discarding17 of old plastic playing fields or landfilling and
closure of landfills18 and SuperFund19 sites, all related activities are often found in
overburdened communities. EJ/SJ communities often have a higher proportion of non-native
English speakers.20 These communities are often left out of the decision making process.21
RESPONSES TO QUESTIONS POSED IN DRAFT DOCUMENT:
Is the following product definition clear and accurate?
Definition: Artificial turf is a synthetic material engineered to mimic natural grass. It is
made of plastic, blade-like fibers woven into a backing.
It would be more accurate to state synthetic turf is a fossil fuel-based petrochemical plastic
product engineered to resemble natural living grass.
Are there additional chemicals in the blades and backing components not discussed in
this document that SCP should evaluate?
There are a multitude of toxic and carcinogenic chemicals found in synthetic turf, including, but
not limited to:
Phthalates22-27
Latex (including
styrene
butadiene)28-33
Polyvinyl
chloride34-36
Naptha 37-39
Siloxanes40,41
Talc42,43
Di/Isocyanates44-46
Formaldehyde 47-49
Fungicides50-54
Flame
retardants55-58
Coal fly ash59,60
Dibutyltin Ethylene
glycol61-63
Anti-microbials 64-66
Colorants67,68
UV stabilizers69-72
Anti-static
treatments73-78
Can you provide information about any ongoing environmental toxicological or exposure
studies on artificial turf?
The Kassotis Lab, Wayne State University, Detroit, MI
Endocrine Disrupting Toxicity Associated with Artificial Turf Materials and Use79-81
The Ecology Center, Ann Arbor, MI80,82,8
Dr. Homero Harari,ScD, Assistant Professor in the Department of Environmental
Medicine and Public Health at the Icahn School of Medicine at Mount Sinai; exposure
scientist in the Senator Frank R. Lautenberg Environmental Health Sciences
Laboratory83,84
Netherlands Ministry of Sport 85
Department of Civil and Environmental Engineering, Norwegian University of Science
and Technology 86
Dr. Genoa Warner, PhD. Environmental toxicologist, Endocrine Disrupting and
Biological Chemistry Lab; New Jersey Institute of Technology, will be conducting
PFAS testing on old synthetic turf samples fall 202487
Public Employees for Environmental Responsibility, Dr. Kyla Bennett, PhD, JD. On going
testing for PFAS in synthetic turf88
Dr. Jimena Diaz Leiva, PhD, Former Director, Center for Environmental Health,
Oakland, CA (PFOS in synthetic turf)89
Dr. Jaime DeWitt, PhD, Director of Pacific Northwest Center for Translational
Environmental Health Research, Oregon State University (PFAS; POPs)90
Dr. Courtney Carrigan, PhD,exposure scientist and environmental
epidemiologist (PFAS)91
Dr.Susan Allen, PhD, chair Department of the Environment, Ithaca College
environmental toxicology; PFAS; microplastics; crumb rubber)92
Dr. Leonardo Trasande,Wagner School of Public Service and NYU’s College of
Global Public Health (Plastics; Phthalates; PFAS; Endocrine disrupting chemicals;
children’s environmental health)93
Dr. Phillip Landrigan, MD MSc;Director of the Program for Global Public Health
and the Common Good; Director of the Global Observatory on Planetary Health
Schiller Institute for Integrated Science and Society (Global Public Health;
Children's Environmental Health; Occupational Health; expert on Plastics)94,95
Dr. Rachel Massey, ScD,Senior Science and Policy Advisor at Collaborative for Health
and Environment and Senior Research Associate at the Lowell Center Sustainable
Production at the University of Massachusetts Lowell96,97
Dr. Zehnyu Tian, PhD, Assistant Professor in the Department of Chemistry and Chemical
Biology, North Eastern University (Environmental chemistry; 6PPD; plastics)98-100
Dr. Graham Peaslee, PhD, Professor Emeritus, Department of Physics &
Astronomy,University of Notre Dame101-103
Dr. William DeHaan, PhD, Oceanography, Marine Management; University of
Barcelona104-105
Dr. Sarah-Jeanne Royer, PhD, Oceanographer, microplastics. Scripps Institute of
Oceanography, La Jolla, CA106,107
Kristen Mello, MSc, analytical chemist (PFAS)108
Dr. Ariane Middel, PhD, engineering. Arizona State University (Tempe); UCLA Luskin
Center for Innovation;President of the International Association of Urban Climate
IAUC); Board member of the American Meteorological Society (AMS) Built Environment
BUE), a member of the International Society of Biometeorology (ISB), and the Institute
of Electrical and Electronics Engineers (IEEE)109,110
Dr. Win Cowger, PhD, environmental scientist, microplastics. Moore Institute for
PlasticPollution Research111,112
Are there any Life Cycle Assessments (LCAs) that evaluate artificial turf in California or
U.S. environments?
LCAs that have been done have been paid for by parties seeking to install synthetic turf, and
like EIRs that are sometimes done under the California Environmental Quality Act (CEQA), are
incomplete; do not recognize synthetic turf as an impervious surface that it has been declared
by the US EPA; do not consider the contribution of greenhouse gasses (cradle to grave and
through complete decomposition) of the plastic carpet and infills; the toxic runoff that occurs;
impacts on biodiversity; contribution to climate change; heat island effect; plastic and
microplastic pollution for centuries. These reports have used fraudulent chemical testing results
done by scientists for hire, false narratives created and perpetuated by industry, false claims
regarding community engagement and surveys and been biased towards the plastic that those
paying for the studies seek to install. They do not include a cradle to grave analysis, do not fully
consider the human health and environmental impacts, the multiple chemical exposures, impact
on vulnerable populations and communities, hidden costs associated with maintenance, repair,
safety testing, infill replenishment, replacement, removal, disposal as well as costs associated
with health care burden and remediation of air, water and soil.
The city of Los Angeles will be conducting such a severely limited LCA, reviewing “installation,
operation and maintenance for different types of turf surfaces,” which again, is not thorough nor
adequate and will not include a full cradle (fossil fuel extraction) to grave (the 1,000 years to
fully decompose 113) analysis.
Chemical Additives
To what extent do artificial turf manufacturers or raw material suppliers have influence
over the chemical additives in their products?
There are multiple companies that manufacture raw materials used in the manufacture of
synthetic turf, including international manufacturers. It would seem logical that synthetic turf
manufacturers have sole discretion over the materials they purchase for use. Even if
participating in a purchasing pool, it would be the responsibility of the parent company to
request information on chemical composition and independent third party testing for
verification for chemicals of concern in the products they purchase for use in manufacturing.
An example of failure to obtain full disclosure took place in Portsmouth, NH in 2019 when a
PFAS-Free synthetic turf field was promised to the city, despite pressure from the community
and expert testimony that no such product existed.114-117
Synthetic turf manufacturers often use chemical additives that chemical manufacturers will not
provide Safety Data Sheets (SDSs) for (eg Dow Chemical) and import yarns and colorants and
other components that those manufacturers will not provide chemical information on despite
requests. Synthetic turf manufacturers then go on to claim that their products do not contain
intentionally added PFAS.”118-125
Synthetic turf made outside of the US may be imported for sale as well.125-128
Also imported are colorants, infills, antimicrobials, such as Triclosan (trade name Microban),
silver nanoparticles additives and more,130-135
Triclosan is registered with the US EPA under the name Microban Additive B and contains 99%
5-Chloro-2-(2.4-dichlorophenoxy) phenol with 1% inert ingredients. It is specifically for use in
polymer plastics and latex.
Triclosan was banned in the US due to its carcinogenic effects on human skin.136,137
One of the most studied chemicals, triclosan, cannot be completely removed by wastewater
treatment plants. It is also found in wastewater effluent and biosolids sold as fertilizer and has
been found world wide in freshwater (effluent and surface water) in concentrations ranging from
0.5 ng/L to 14 mg/L. It is an endocrine disruptor, persistent in the environment and
bioaccumulative in both non aquatic and aquatic organisms.138
TCS's [triclosan’s] potential for endocrine disruption, as the antimicrobial has been
shown to disrupt thyroid hormone homeostasis and possibly the reproductive axis.
Moreover, there is strong evidence that aquatic species such as algae, invertebrates and
certain types of fish are much more sensitive to TCS than mammals. TCS is highly toxic
to algae and exerts reproductive and developmental effects in some fish. The potential
for endocrine disruption and antibiotic cross-resistance highlights the importance of the
judicious use of TCS.”139
Methyl-triclosan presents a greater potential for bioaccumulation than triclosan.
Triclosan was detected in all samples, at concentrations (5–27 g kg 1) comparable to
values found in other surface sediments under the influence of marine wastewater
outfalls. Its dispersal was closely associated with fine and organic-rich fractions of the
sediments. Methyl-triclosan was detected in approximately half of the samples at
concentrations <11 g kg 1. The occurrence of this compound was linked to both
wastewater discharges and biological methylation of the parent compound.”140
Triclosan was shown to be toxic to Ampelisca abdita and Americamysis bahia in water only and
sediment exposures. The chemical was also shown to accumulate in tissues of these estuary
sediment dwelling organisms.141 It was confirmed to be toxic to microalgae in biofilms in a 2014
Swedish study.142
After years of efforts to conceal research showing the toxicity of triclosan and other pollutants on
the part of the chemical industry 143 and mounting concerns and frustrations over lack of
progress towards regulation,144 more than 700 medical professionals, scientists and non profit
organizations met in Florence, Italy on 28 Aug 2016 for the 36th International Symposium on
Halogenated Persistent Organic Pollutants (DIOXIN).145 More than 200 signatories from 29
countries, including many well known to CA DTSC, developed the Florence Statement on
Triclosan and Tricloroban.146,147
On 2 September 2016, the final day of the Symposium in Florence, after many years of waffling,
the US FDA issued its final rule, banning triclosan and triclorocarban, leaving the field wide
open for additional uses.148
This final rule applies to consumer antiseptic wash products containing one or more of
19 specific active ingredients, including the most commonly used ingredients – triclosan
and triclocarban. These products are intended for use with water, and are rinsed off after
use. This rule does not affect consumer hand “sanitizers” or wipes, or antibacterial
products used in health care settings.”149
In 2017 a Danish study showed that exposing the copepod Acartia tonsa to microplastics and
triclosan was more toxic than microplastic or triclosan exposure alone, demonstrating a clear
synergistic effect.150
Wu, Ji, Zahng et al (2018) were able to determine the toxicity and fate of triclosan in wastewater.
Using gas chromatography-mass spectrometry (GC–MS) and high resolution gas
chromatography-high resolution mass spectrometry (HRGC-HRMS), exposing a matrix of
seawater and active chlorine to UV light, triclosan rapidly degraded to tetraclosans and
pentaclosans, with the formation of five dioxins, including 2,8-DCDD, 1,2,8-TrCDD,
2,3,7-TrCDD, 1,2,3,8-TeCDD, and 2,3,7,8-TeCDD, were identified and quantified. The most
toxic dioxin, 2,3,7,8-TeCDD, was the first to form.151
In a Spanish study on microplastics, published in 2020, the ability of triclosan to adsorb and
and desorb from microplastic particles of Low Density Polyethylene (LDPE), polyamide (PA)
and polyoxymethylene (POM) to aquatic biota, cyanobacterium Anabaena, showed a significant
decrease in growth (LDPE 22.3%; PA 94.6%; POM 81.0%) and chlorophyll content (LDPE
58.4%; PA 95.0%; POM 89.6%). Cyanobacters are significant components of phytoplankton
and therefore essential to the food chain.138
A study from China released in 2020 showed that polyhydroxybutyrate (PHB) and triclosan
easily desorb from microplastics under physiological conditions. As with the 2020 Spanish
study, the researchers find that aquatic organisms that ingest microplastics with adsorbed
triclosan can become vectors as the toxic chemical desorbs into tissue, bringing risk to the
environment and human health via the food chain.152
It is overwhelmingly clear that because a product is colored green or the industry otherwise
greenwashes their advertising and sales pitch, that this product is unsafe to humans and the
environment alike. Millions of pounds are poured into and onto plastic grass surfaces annually,
exposing children, athletes and wildlife and washed into waterways and the ocean.
The burden should not fall on the consumer to ascertain the chemicals hidden behind
Confidential Business Information (CBI). Parents and caregivers, rightly or wrongly, have an
expectation that if a product is available for purchase, that its safety has been verified. They
also, again, rightly or wrongly, have the expectation that information provided by manufacturers,
trade organizations and affiliated industries is objective, truthful and based on independent,
verifiable research and sources. None of this could be further from the truth as it pertains to the
synthetic turf industry.
The synthetic turf industry, which is unregulated in any state, and has not self-regulated in 60
years, has no incentive to provide full disclosure of the toxicity of their products. They have
developed a pattern of issuing signed affidavits118-125 regarding PFAS and the heavy metal lead
with impunity. They have also left requests regarding use of phthalates, the number of fields
installed and locations of so called recycling facilities unanswered all while making numerous
false claims regarding “eco-friendly,” low maintenance, water saving, ability to drain truly
outrageous amounts of rain, ability to cool surface temperatures to safe levels for play- all
reportable as greenwashing to the California Office of the Attorney General and the Federal
Trade Commission. It does not behoove DTSC to repeat these false claims, as was done in the
background document. It is also imperative that DTSC not allow continuation of such practices.
Is there additional information on PFASs being intentionally added during the
manufacturing of artificial turf?
Yes. Independent third party testing consistently shows the addition of PFAS to synthetic turf.
Culled from public records, 32 PFAS have been found to date with independent testing:
D2-N-EtFOSAA
D3-EtFOSA
D9-EtFOSE
6:2 FTS
6:2 FTSA
7:3 FTCA
8:2 FTOH
12C2-4:2 FTS
13C2-6:2 FTS
13C2-8:2 FTS
GenX
D3-MeFOSA
D3-N-MeFOSAA
D7-MeFOSE
MTP
PFBA
PFBS
PFDA
PFHpA
PFHxA
PFHxS
PFNA
PFOA
PFOS
PFPeA
PFPrA
PFTrDA
PMPA
PPF Acid
PTFE
PVDF
R-EVE
PFOS was found on the hands of young soccer players who played on synthetic turf in a small
pilot study in San Diego in the summer of 2023.153 That study is currently being replicated by the
Kassotis Lab, Wayne State University with 50 student athletes.
On 4 March 2024, and reissued on 10 May 2024, the Center for Environmental Health (CEH),
Oakland, CA, issued a 60 day Notice of Intent (NOI) to sue Lowe’s, Home Depot and others
under the California Clean Air and Water Act (Prop.65) for PFOS in synthetic turf they sell.154,155
Recent communication with CEH indicates this lawsuit is moving forward. The number of
lawsuits involving PFAS and other toxic chemicals in synthetic turf will only grow.
Of high significance, a study done by the Kassotis Lab, in conjunction with The Ecology Center
Ann Arbor, MI), “In vitro endocrine and cardiometabolic toxicity associated with artificial turf
materials”in the October 2024 edition of Environmental Toxicology and Pharmacology,
demonstrates not only the cytotoxic effects of chemicals in synthetic turf to endocrine organs
and cardiac development and function.77-79 This study also demonstrates the importance of
looking at combined chemical exposures associated with a given product. No one is ever
exposed to one chemical- certainly not with plastics and definitely not with synthetic turf.
Artificial turf is made of a chemically complex set of materials that release a range of toxics,
including volatile organic compounds (VOCs), phthalates, bisphenols, microplastics, metals
and more. Although many of these are known endocrine disrupting chemicals, little work has
been done to characterize the health effects of most turf components, meaning more
research is needed to better understand the potential hazards of exposure to artificial turf.”157
PFAS has been documented to leach from synthetic turf fields and contaminate water.157-168
PFAS contamination is costing billions of dollars to clean up water in California.169-172 The
industry and owners of plastic fields and yards should be held accountable and made to pay, not
the taxpayer.
Polymer processing aids:
There are multiple examples of PPAs specifically manufactured for use in synthetic turf:
3M Corporation172-177
3M Dynamar FX 5922 has been used by the manufacturer FieldTurf. This PPA has now
been removed from 3M’s catalog.177
Dow Chemical178-185
PVDF186
The need to stop further PFAS exposure cannot be overstated. PFAS187 can cause multiple
reproductive disorders 188 (including a 40% decrease in female fertility 189; a decrease of 62.3%
total sperm count in males190; Crohn’s disease191; breast192, testicular, kidney, prostate193 and
liver194 cancers. They cross the blood-brain barrier and are related to Autism Spectrum
Disorder196, Attention Deficit Hyperactivity Disorder 197, increased deaths from Parkinson’s and
Alzheimer’s diseases198; immunological effects199; increased serum cholesterol200; effects on
infant birth weights201; impaired glucose metabolism, insulin resistance, dyslipidemia and
adiposity in children and adolescents 202; thyroid hormone disruption 203 (including neonatal) and
thyroid cancer 204. Because they are bioaccumulative, PFAS exposure can impact multiple
generations205. Babies are being born pre-polluted with PFAS206.
UV Stabilizers 207,208
Flame Retardants209-211
Are side-chain fluorinated polymers or other PFASs besides fluoropolymers intentionally
added to artificial turf?
Side-chain fluorinated polymers are found in many consumer products.212
Patents and third party independent testing indicate that side-chain fluorinated polymers and
other PFAS are added to or leach from synthetic turf.213-221
fluoroelastomers
Preferably, the polyethylene composition comprises a processing aid, for example a
fluoroelastomer. In some preferred embodiments, the polyethylene composition comprises at
least 0.2% to at most 2.0% by weight of a processing aid, for example a fluoroelastomer,
preferably at least 0.5% to at most 1.5% by weight, based on the weight of the polyethylene
composition. The properties of final polyethylene composition may be obtained from the
final resin (which includes optional polyethylene-based composition C and optional additives),
or from the resin prior to addition of any masterbatches (such as polyethylene-based
composition C) and/or any additives.”222
acrylates (SynLawn patent)223
urethanes (SynLawn patent)224
silicones225-227
ethoxylates227-230
Is there information on ortho-phthalates being intentionally added during the
manufacturing of artificial turf?
Phthalates are used extensively in the manufacturing of plastics. They have endocrine
disrupting231 as well as neurotoxic232 effects. As plasticizers, they are used in plastic toys,
playground equipment, “natural rubber” and tire manufacturing 233. Use of phthalate-containing
products is choosing to risk impairment of children's I.Q.s, their brains and their overall health.
Phthalates are both endocrine disrupting chemicals (like PFAS) and neurotoxins.
Ortho-phthalates are diesters of phthalic acid and are the predominate type of
phthalate used in commerce. (For simplicity, we will refer to them as phthalates.)
They are high-production-volume chemicals used most often as a plasticizer in
polyvinyl chloride (PVC) and other plastics.Phthalates are used in numerous
consumer products, including food production materials and packaging; medical
supplies and coatings of medicines; flooring, wall coverings, and other home
materials; and cosmetics and other personal care products. Approximately 4.9
million metric tons are produced annually worldwide. The highest-production
phthalates are di-2-ethylhexyl phthalate (DEHP), diisononyl phthalate (DiNP),
butylbenzyl phthalate (BBzP), dibutyl phthalates (DBPs), and diethyl phthalate
DEP).”232
The US EPA has begun the process to ban PVC.234,235
Phthalates are used extensively in the manufacturing of synthetic turf.236-240
Identify state-specific data on the total amount of artificial turf used in California.
In a 2024 presentation to CalRecycle, Tarkett Sports reported 850 million square feet of plastic
grass carpeting is installed in North America annually, with 45% being for use as sports fields.241
There is no state law requiring tracking and tracing of installations, removals and final (not
interim) disposal of plastic playing fields. There is inconsistency in requirements regarding
permit applications for installation and/or removal of synthetic turf from city to city and county to
county. This is made more complex by the wide variety of settings and agencies that use
synthetic turf:
landfill cover
turf242,243
Superfund sites244
highway
embankments
sports parks
playgrounds
residential
applications
commercial
applications
daycare centers
spas
balconies
gyms
airports (indoors
and out)245
golf courses and
centers
batting cages
street verges and
medians
waterway lining 246
storm drain
outlets247,248
Turf reinforcement mats, as used for lining of waterways, storm outlets and high erosion slopes
are geotextiles and may be made of polyethylene, polypropylene, PET and may be made from
recycled plastics- all of which pose significant risk to the environment via chemical leachate and
microplastic degradation.249,250
Additionally, school districts, cities and counties may evade California Environmental Quality Act
requirements by
i) Not filing required documents via the CEQAnet portal
ii) Cherry picking which agencies to report to (not filing with DTSC being one example)
iii) Providing false information on project(s)
iv) Declaring Mitigated Negative Declaration(s)
v) Filing Notice(s) of Exemption
Legal recourse becomes a financial burden on taxpayers who seek remedy by filing a lawsuit.
The amount of waste artificial turf generates is expected to rise because a growing
fraction of turf installations are replacements rather than new fields (Berger 2016). These
replacements accounted for an estimated 22% of the 1,200 to 1,300 fields installed in the
United States in 2013 and around 50% of the 1,500 fields installed in 2015 (Berger 2016).
About 40,000 pounds of turf and 400,000 pounds of infill are used for an average field
STC 2017).
There are 3 known surveys on synthetic turf installations in parks and schools:
San Diego County (schools; parks; public spaces); 14,237,244 sq feet; 326.842 acres
New Jersey, State District 21; 34,484,800 sq ft; 80 acres
Maryland - Dec 2021; 24,300,000 sq feet; 557 acres
In 2010, the industry reported greater than 6,000 playing fields in the US. In 2017, they reported
Currently, there are between 12,000 and 13,000 synthetic turf sports fields in the U.S., with
approximately 1,200 – 1,500 new installations each year.” In their 2020 Industry Market Report,
STC (Synthetic Turf Council) claimed from 2017- to June 2020, industry growth of 15 percent
and “approximately 265 million square feet of installed turf and 777 million pounds of
infill”251…added to the carbon footprint in the US in the span of 2.5 to 3 years.
On 12 July 2021, interns in Maryland working on a survey of school and park installations of
synthetic turf across the state spoke with a representative from FieldTurf (a Tarkett company
and manufacturer of synthetic turf). That individual reported there were 29,700 fields installed
in the U.S. (with crumb rubber infill). At 1200 to 1500 new fields installed per year, that would
put the current number of fields at approximately 33,300 to 34,200.
Information provided by Tarkett in at the CalRecycle Tire Conference 19-20 June 2024241
850 million SQF / year of Artificial Turf installed In North America
45% of new installations are “SportTurf”
41% of synthetic turf installed globally are replacements
Artificial turf may include additional materials, depending on the intended use. Layers of
hidden material underneath the surface aid in drainage and provide padding but are not
required (Jastifer et al. 2019). Infill material between the blades – most commonly rubber
or silica sand – also provides cushioning (Jastifer et al. 2019; STC 2022).
Artificial turf is considered impermeable by the US EPA and state of California.252,,253
areas such as gravel roads...that will be compacted through design or use to reduce
their impermeability.”It further has defined impervious surfaces as…[a]ny surface that
prevents or significantly impedes the infiltration of water into the underlying soil. This can
include but is not limited to: roads, driveways, parking areas and other areas created
using non porous material; buildings, rooftops, structures,artificial turf and compacted
gravel or soil.”
Compaction, as well as the impervious plastic surface, result in increased runoff. Despite
synthetic turf industry claims, laboratory testing is not the same as reality. Synthetic turf is
unable to handle the amount of rain that comes with an atmospheric river or bomb cyclone.
With 12 atmospheric rivers since December 2022 (Scripps Institute of Oceanography, UC San
Diego reports 29), predictions of a coming El Niño, increasing frequency and severity of
atmospheric events overall, consideration of synthetic turf is antithetical to environmental
responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years
on average.
Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until
runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into
stormwater drains and directly to local waterbodies. As impervious surfaces increase,
stormwater runoff increases in quantity, speed, temperature, and pollutant load. When
impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and
continues to increase until, at 100% impervious surface coverage, runoff is five times
that of a forested watershed. Excessive stormwater runoff also increases the potential
for flooding.”
The industry’s often outrageous claims, of synthetic turf’s ability to drain are not scientifically
proven in real life events, such as those we are currently experiencing with atmospheric rivers,
bomb cyclones, flooding and landslides.254
Synthetic turf is a contributor to climate change via off gassing of methane, ethylene and carbon
dioxide and thereby contributors to climate change,255,256 heat islands and catastrophic events
such as atmospheric rivers and bomb cyclones. Always hotter than other impervious surfaces,
it also contributes to thermal burns, exertional heat illness, including heat stroke and death, and
impacts on wildlife and soil biome.
Scripps Institute of Oceanography, University of California San Diego reported 46 total
atmospheric rivers 257 along the U.S. West Coast, causing disastrous flooding and loss of
property and life during the 2022 to 2023 rainy season. With what has now been categorized as
a Super El Niño year currently, increasing frequency and severity of atmospheric events overall,
consideration of synthetic turf is antithetical to environmental responsibility and an even poorer
choice for a product that must be replaced every 8 to 10 years on average.
Heat and chemical off gassing:
This is a climate damn emergency’
Gov. Gavin Newsom
The overheating of densely crowded and overbuilt urban centers258 points to the desperate and
unmet need of open natural green spaces if the effects of climate change are to be mitigated.
Synthetic turf can readily become much hotter than asphalt, reaching temperatures of 1600F to
1800F (regardless of infill type; higher temperatures when a shock pad is placed under the
plastic carpet) and have even reached well in excess of 222.8oF (106oC) Thermal burns on
plastic turf have even required hospitalization.
At a surface temperature of 118°F a first-degree thermal burn occurs in 15
minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a
temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns
in 5 seconds.259
An estimated 9,000 student athletes260 are treated for exertional heat illness each year. The
reduced functional level created by heat from synthetic surfaces, even at reasonable ambient
temperatures can contribute to injuries due to compromised functional level.
As the planet heats up, athletes are increasingly impacted by heat related illness by playing on
synthetic surfaces. Deaths among high school football players from heat stroke doubled from
2015 to 2017 when compared to the 5 preceding years. Football players are eleven times more
likely to suffer a heat related illness.261 Playing on synthetic turf is a contributing factor.
After traumatic injuries and cardiac related events, heat illness is the 3rd leading cause of death
among teenage athletes. One of the predisposing factors are prescription drugs for treatment of
attention deficit hyperactivity disorder, ADHD, which can be caused by PFAS chemicals found in
plastics.197
Phoenix June 2021 Phoenix June 2021 Los Gatos, CA June 2024
Geofill Infill Geofill Infill Used Tire Crumb
117oF ambient air Same field/day/time 105oF ambient air
Children are not small adults. They are more readily impacted by heat illness262 due to:
Heat production – Children have higher metabolic rates than adults which leads to
higher production of more heat.
Body surface area – Younger children absorb more heat because they have a greater
body area to body mass ratio. For older children and teens, increased body fat and low
fitness levels are contributing factors.
Blood circulation – Children are less able to cool their body temperature by shunting their
blood from their body core to their body surface due to lower cardiac output and smaller
blood volume.
Sweat production – Children produce less sweat per gland and sweat at higher body
temperatures than adults.
Fluid replenishment – Children are less likely to self-regulate hydration if unsupervised.
Children experiencing heat illness are most likely to present with significant neurological
symptoms- from delirium, hallucinations, poor muscle control and unsteady gait, difficulty
with speaking or unclear speech to seizures or coma. These symptoms may be readily
confused with head trauma, epilepsy or drug overdose. Mortality is high and if a child
survives heat stroke, their risk for recurrence of heat illness is increased.
Synthetic turf off-gasses both methane and ethylene and continues throughout the night, in ever
increasing amounts for the 1,000 years it takes for it to decompose. Methane traps 90% more
heat than carbon dioxide and is 21 times more potent. Land based plastics produce 2 times
more methane and 76 times more ethylene than plastics found in waterways and oceans.255
The heat islands created by plastic turf playing fields are large enough to be visible from
satellites circling our planet.Even if all synthetic turf were removed from California today, the
methane would linger in the atmosphere for approximately 12 years, contributing to climate
change and sea level rise for hundreds of years after the pollutants have been cleared from the
air.
UC Davis sports fields Crocker Amazon Soccer Fields, San Francisco
Rosemont High School, Rosemont, CA / Minnie & Lovie Ward Rec Center, San Francisco, CA
Covering the earth in toxic green plastic is not consistent with the California Climate Adaptation
Strategy,263 nature based solutions to the climate crisis,264 and it is counter to the objectives of
the State’s Extreme Heat Action Plan.265
Further, the off gassing and leaching of toxic and carcinogenic chemicals from petrochemical
synthetic turf continues for centuries after its “useful” life.266
OEHHA is currently conducting an assessment of potential health impacts associated
with exposures to chemicals released from artificial turf and crumb rubber (OEHHA 2015)
OEHHA’s study, which began in 2015 and is not yet complete and focuses on used tire crumb
infill, used in 97% of synthetic turf playing fields.
This study focuses on exposure to crumb rubber infill.”267
Plants and soil biota near artificial turf may also be impacted by Candidate Chemicals
leaching out of microplastics from weathered artificial turf blades or backing (Ding et
al. 2022; Li 2019). For example, artificial turf blades can release (i.e., leach)
ortho-phthalates, metals, and organic compounds when exposed to water (Plesser and
Lund 2004). Additionally, off-gassing of volatile [gasses].
The use of shock pads under synthetic carpet must be taken into consideration as well.
There is an ever increasing amount of information and research regarding microplastics and
chemical leachate into our environment, negatively impacting the soil biome, water and air
quality and threatening biodiversity and the food chain. The multiple negative impacts on health
and the environment from this product cannot be understated.268-276
End of useful life
Reuse is more common with artificial turf infill than with the blades and backing
Zandwijk RTS 2022).
Landfill disposal is a concern because of the large mass of waste involved. The
roughly 40,000 pounds of turf and 400,000 pounds of infill used in a single average
field (STC 2017) has the potential to leach or off-gas significant quantities of
hazardous compounds over time.
Incineration is another potential form of disposal, but it is problematic because
the fluoropolymers in artificial turf can form toxic combustion products (e.g.,
halogenated benzene and naphthalene compounds) (Myers et al. 2014). Also,
incineration only accounts for a small portion of overall waste management in the
United States (U.S. EPA 2016b).
Less than 6%of plastics are recycled.277 Made of mixed plastics, synthetic turf is not recyclable,
not sustainable and is a linear, not a circular, product.
A lobbyist for The Synthetic Turf Council gave testimony278 in the California Senate Finance and
Governance Committee on 12 July 2023 stating:
One thing we don't want to do is to set a [PFAS] limit that's so low that we can't recycle
the products because you're going to have environment--I mean, PFAS is
everywhere--so you're going to have environmental PFAS that's out there. We want to
still be able to recycle products. We don't want to have a situation where we're no longer
able and it has to go to the waste stream instead of be[ing] recycled in some way.”
The same lobbyist testified in the California Senate Environmental Quality Committee on 19
June 2024, stating that the largest carpet recycler in Los Angeles cannot recycle synthetic turf.
The Trex Company, in a 2022 email, stated they will not accept synthetic turf for use in
manufacturing of their composite wood/plastic fencing and decking due to the environmental
contamination of the plastic fields.
One “recycler” with grandiose claims that it would be able to [mechanically] “recycle” 60k tons
of synthetic turf per year (3,000 regulation sized 80k square feet fields; 40,000 pounds for
carpet and backing; 400,000 pounds of infill), obtained tax incentives in both PA and CA. They
have failed to open a plant in either state, and have never recycled a single old field into a new
field in their home country of Denmark. With an estimated 30,000 synthetic turf fields in
existence in the U.S., it would take 10 years to recycle the current fields with no new fields
brought into the market.
When “mechanically” recycled (chopped up, essentially) for use in other products, the toxic and
carcinogenic effects are added to the new product, along with additional toxic and carcinogenic
chemicals. Downcycling plastics into new products creates new, lesser quality products that are
not recyclable.
Research (2023)279 from a single northern Scotland recycling facility that accepts 22,680 tonnes
of mixed plastic waste annually showed mechanically recycling plastics resulted in the release
of up to 3,000,000 pounds of microplastics into the environment in a single year. The
implications of this research indicate “…as much as 400,000 tons [800,000,000 pounds]per
year in the United States alone, or the equivalent of about 29,000 dump trucks of microplastics.”
Three other companies, TenCate280 FieldTurf281 and Target Technologies International, Inc.,
claim they are shipping chopped up old carpets to Cyclyx in Houston for further processing, then
to ExxonMobil in Baytown, TX for “advanced chemical recycling,” where the plant is fraught with
millions of dollars in fines for violations. The failed scheme was recently exposed.282,283
When shipped out of state for “advanced chemical recycling” (banned in CA under SB54-Allen,
2022), they contribute to the negative human and environmental health effects of Environmental
and Social Justice (EJ/SJ) communities. Landfilling and dumping used rolls also often occurs in
EJ/SJ communities.
removed from website after email inquiry)
Even the so-called mechanical recycling of this product is unregulated in CA, posing a risk to
workers and the environment. In communication with CalRecycle regarding a facility in Lincoln,
CA:
By statute (Public Resources Code §40194 & 40200(b)(2)), facilities whose primary
function is to process wastes that have already been separated for reuse and are not
intended for disposal are not included in the definition of a transfer/processing facility
and thus not a solid waste facility. Title 14, California Code of Regulations, Section
17402.5(d), lists the activities that are not subject to transfer/processing regulations
which include a recycling center that meets certain conditions known as the "Three-Part
Test." If a facility fails any of the Three-Part Test, then it would be regulated by the LEA
as a solid waste activity. The Three-Part Test provides:
1. An activity shall only receive material that has been separated for reuse prior to
receipt.
2. The monthly average of the residual amount of solid waste left after processing
the material received at the facility is less than 10 percent by weight.
3. The amount of putrescible wastes in the material is less than 1 percent of the
amount of separated reuse material received by weight, and the putrescible
wastes shall not cause a nuisance.
At present, there is not a state program in place that is designed specifically to manage
the recycling of synthetic turf. Therefore, the Three-Part Test is used to determine
whether a facility is operating as a solid waste facility or operation or a recycling center.
If a site is a Three-Part Test recycling center, the LEA can require the operator to
regularly show evidence that the site continues to meet the exclusion requirements. If at
any time the LEA determines that the site cannot meet the exclusion requirements, the
site would be regulated as a solid waste site.”
Communication with the local enforcement agency (LEA) for Placer County284 indicates they do
not regulate this facility and that recyclers are excluded from permitting.
Lawsuits have been filed in San Francisco Superior Court against ExxonMobil for false recycling
claims on 23 September 2024 by the California Office of the Attorney General,285
with a second lawsuit filed in the same court by non-profit organizations Sierra Club. Inc.
Surfrider Foundation, Inc., Heal the Bay, INC. and Baykeeper, Inc..286
Failure to regulate recycling of synthetic turf allows the fossil fuel, petrochemical and plastics
industry to continue exploiting both people and the environment for profit through continued use
additional virgin plastic and toxic chemicals; concealing toxic microplastics in new downcycled
products; perpetuation of cradle to grave use of toxic fossil fuel petrochemical plastics;
perpetuation of plastic’s impact on climate change, biodiversity loss and centuries of micro- and
nano plastic pollution.
Once past its “best by” date, this petrochemical product is often resold on CraigsList, FaceBook
MarketPlace and Turf Cycle USA287 or is otherwise warehoused or improperly or illegally
discarded.
San Martin, CA Pescadero, CA
Different additives in artificial turf may have different long-term environmental fates
Kwon et al.2017).
fluoropolymers are not expected to be highly leachable or mobile in the
environment (Henry et al. 2018)
their eventual release from artificial turf is expected to increase over time due to
weather exposure and frequency of turf use (Lohmann et al. 2020).
Fluoropolymer particles degrade into microplastics and have the potential for
long-distance environmental transport, *polytetrafluoroethylene (PTFE) in
deep-sea arctic sediment (Bergmann et al. 2017).
Fluoropolymers are not benign.
High use fluoropolymers include ethylene propylene (FEP), perfluoroalkoxy alkanes
PFA), ethylene tetrafluoroethylene (ETFE)m polytetrafluoroethylene (PTFE aka Teflon),
polyvinylidene fluoride (PVDF), polyvinyl fluoride (PVF), and fluoroelastomers.Like
side-chain fluorinated polymers and poly- or perfluoropolyethers, fluoropolymers are
polymeric PFAS that emit toxic gasses during production, use and through final disposal
and decomposition. They are highly persistent in the environment.288
Microplastic PTFE particles have been found in the Arctic sediment and fish in the
Mediterranean Sea.289,290
There is a call for fluoropolymer use to be limited to strictly essential use due to human
risk associated with their use. Synthetic turf is not a necessary use by any measure.
Ortho-phthalates do leach from products (Plesser and Lund 2004; Prasad 2021), but they
are only expected to be persistent under certain environmental conditions
Ortho-phthalates pose significant risks to human health:291
oxidative stress
estrogenicity
antagonism to
androgens
gestational, adult
diabetes
cardiovascular
mortality by
decreasing
testosterone levels
in adult men
infertility
childhood and adult
obesity
cardiovascular
disease
breast and thyroid
cancers
endometriosis
lipid and
carbohydrate
metabolism
increases in
prematurity
Ortho-phthalates can also:292
impair brain development
increase risks for learning, attention, behavioral disorders in childhood.
adverse effects on male reproductive tract development
There is a clear mandate for immediate action.293,294
chronic exposure to phthalates will adversely influence the endocrine system and
functioning of multiple organs, which has negative long-term impacts on the success of
pregnancy, child growth and development, and reproductive systems in both young
children and adolescents. Several countries have established restrictions and
regulations on some types of phthalates; however, we think that more countries should
establish constraints or substitute measures for phthalates to reduce health risks.”
Microplastics:
recycling of artificial turf may result in microplastic pollution.
recycling facilities have developed processes to recycle the plastic blades,
backing, and infill of artificial turf (Re-Match 2022; TenCate Grass 2022) plastic
recycling facilities may be problematic.
recycling facilities may be a major source of microplastic pollution in receiving
waters, particularly molecules smaller than 10micrometers (Brown et al. 2023).
workers at plastic recycling facilities may be exposed to microplastics through
inhalation (Brown et al. 2023).
Research in China has demonstrated that microplastics can reach virtually all
waterways (Zhang et al. 2018); (microplastic release from artificial turf may have
far-reaching effects)
artificial turf additives travel with microplastics; expected to be related to the
chemical structure of these additives(Kwon et al. 2017).
Research by the Department of Civil and Environmental Engineering, University of California,
Los Angeles, and the Moore Institute for Plastic Pollution Research, Long Beach, found
Children's playgrounds contain more microplastics than other areas in urban parks.”295
In addition to the CA Statewide Microplastics Strategy - Senate Bill No.1263 (Chapter 609,
2018),296 CA DTSC recently announced its intent to add Microplastics to the Candidate
Chemicals List.297
Microplastics not only leach chemicals, including PFAS, they adsorb other chemicals and
bacteria, posing particular risk to the food chain. Even the best BMPs (Best Management
Practices) will capture only a small percentage of the microplastics and virtually none of
the PFAS and other toxic chemicals from synthetic turf. Drainage systems are not expensive
granulated activated carbon (GAC) filters.
In humans, micro- and nano-plastics have been found in:298-307
Heart
Liver and spleen
Lungs
Blood
Placenta (maternal and fetal sides)
Newborn and adult feces
Breastmilk
Brain
Penis, Testes and semen
Kidney
Brain
Uterus
Microplastic blade loss from synthetic turf is estimated at 551-661 pounds per regulations sized
playing field per year.308
Microplastic synthetic turf blades have been found in Lake Tahoe (personal email
communications with researchers at Tahoe Environmental Research Center (TERC)) and the
ocean. In 2021, researchers found that synthetic turf fields in Toronto contribute the 2nd highest
amount of microplastics to the environment with only litter contributing a higher amount.309 This
makes synthetic turf a major source of PFAS and microplastic pollution that cannot go
unaddressed. Lake Tahoe researchers found high levels of polyethylene and polypropylene in
the lake and “…recorded plastics concentrations more than three times higher than those
sampled using a similar method in the North Atlantic subtropical gyre.”310
Published on 29 June 2023, research by the University of Barcelona311 found:
AT [artificial turf] fibers - composed mainly of polyethylene and polypropylene - can
constitute over 15% of the mesoplastics and macroplastics content, suggesting that AT
fibers may contribute significantly to plastic pollution. Up to 20,000 fibers a day flowed
down through the river, and up to 213,200 fibers per km2 were found floating on the sea
surface of nearshore areas. AT, apart from impacting on urban biodiversity, urban runoff,
heat island formation, and hazardous chemical leaching, is a major source of plastic
pollution to natural aquatic environments.”
This research leading to the California Coastal Commission's decision to not allow synthetic turf
use in the coastal zone at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not
superior to natural grass and is not sustainable.
Seabin Foundation’s Ocean Health Lab reported that within the first four months of 2024, it
recorded 194 artificial plants and 938 artificial grass fibres (> 5mm) captured in Seabins
around Sydney Harbour. Shockingly, this represents only 10.27% of what Seabins are capturing
daily, and this would equate to approximately 1,992 artificial plants and 9,633 artificial grass
fibres captured in all the 32 Seabins in four months, which again, is only a sample of what’s
entering the Harbour. This suggests the amount of artificial plants and grass polluting our
waterways and the Ocean is much, much higher.”312
The evidence of the negative impact of microplastic pollution on environmental health is equally
daunting. From zooplankton, krill and whales to bees, and terrestrial animals of the Americas,
macro-, micro- and nanoplastics are impacting aquatic and wildlife, and even our pets.
Synthetic turf and microplastics have caused a decrease in bird populations, accumulation of
microplastics on bees and negatively impacts ocean habitats and biodiversity both above and
below ground. Research from 2021 estimated that >1500 species have ingested
microplastics.313
Alternatives to the Candidate Chemicals used as additives
a) PFAS
i) boron nitride -
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10174278/
https://www.intechopen.com/chapters/81202
https://www.sciencedirect.com/science/article/pii/S0048969723033673
ii) thermoplastic urethane elastomers
https://www.osha.gov/isocyanates
iii) polyethylene terephthalate (PET)
https://pubs.acs.org/doi/10.1021/acs.estlett.1c00559
https://link.springer.com/article/10.1007/s12012-024-09837-6
https://www.sciencedirect.com/science/article/pii/S0160412022001258?via%3Dihub
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9562888/#B242-cancers-14-04637
iv) alteration of engineering processes
b) Ortho-Phthalates
i) citrate-derived plasticizers
https://pubmed.ncbi.nlm.nih.gov/32678732/
ii) polymeric plasticizers
https://pubmed.ncbi.nlm.nih.gov/36969097/
iii) coating of surface
SHPFI questions any potential use or release into the environment an anticoagulant
blood thinner) for use in non-medical plastic application.
iv) terephthalate
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9562888/#B242-cancers-14-04637
https://pubmed.ncbi.nlm.nih.gov/36969097/
v) epoxy
https://pubmed.ncbi.nlm.nih.gov/36969097/
https://www.artresin.com/blogs/artresin/how-dangerous-is-your-epoxy-resin#:~:text=Epo
xy%20resins%20can%20be%20harmful%20if%20not%20used,as%20environmental%2
0harm%20if%20not%20handled%20with%20care.
vi) aliphatic compounds
https://dtsc.ca.gov/wp-content/uploads/sites/31/2021/06/HHRA-Note-12-Petroleum-June
2021-A.pdf
https://onlinelibrary.wiley.com/doi/10.1002/0471125474.tox049.pub3
vii) benzoate compounds
More specificity is needed
https://www.ewg.org/news-insights/news/2024/02/what-sodium-benzoate
With over 84,000 chemicals in commerce and only 200 having been tested for safety314
and exceptionally few studies that look at combinations of chemicals, despite knowing that even
non-toxic chemicals can act synergistically to cause cancer, SHPFI urges DTSC to not up the
ante of exposing people and the environment to potential regrettable substitutes.
Will swapping out chemicals decrease synthetic turf's impact on climate change? On loss of
biodiversity? On the effects of natural transpiration, ground water recharging carbon
sequestration and oxygen production? Will these alternative chemicals support a living soil
biome so necessary for life on earth? Will they reduce the reliance on fossil-fuels? Will they
remove all toxic leachate? Will they reduce microplastics in the environment? In humans, wild
and aquatic life? The food chain? Will they reduce plastic production and plastic pollution?
SHPFI strongly objects to continuing to use children, other vulnerable populations, EJ/SJ
communities and wild and aquatic life, as guinea pigs so that the fossil fuel, petrochemical and
plastics industries can continue to profit while ignoring or otherwise greenwashing impacts on
human and environmental health.
Moving forward to regulation:
Disclosure of chemical composition and independent third party testing by commercial
and/or academic laboratories, using testing standards and testing laboratories
designated by CA DTSC must be a requirement under regulation.
New testing should be required anytime there is a change in formulation in the chemicals
procured for and used during or post manufacturing to avoid regrettable substitution of
chemical components or testing methods.
Regulatory requirements must be updated in a timely manner to reflect drinking water
standards for PFAS and POPs established by the State and in accordance with current
state of independent peer reviewed science, evolving public health goals and technology
that allows detection of more toxic chemicals at increasingly lower levels.
Regulation should require disclosure of CBI and chemical bearing patents.
Regulation should include a mechanism to track and trace installation, removal and
through final disposal. We ask that DTSC work with legislators to ensure this process.
Regulation of so-called mechanical recycling facilities must occur. DTSC must work with
CalRecycle and legislators to ensure this regulation.
Synthetic turf must be declared hazardous material. Regulation should be reflected in
transport into and within the state, as well as transport to landfills and/or out of state.
Regulation should require notification of all purchasers, owners and users of synthetic
turf, whether new, donated or resold. DTSC should work with OEHHA to unsure
notification and signage applies in all instances and locations, including state and local
agencies, parks and schools
Regulation should require schools and all fairgrounds and other locations where
synthetic turf is installed be included in small municipal Separate Storm Sewer System
MS4) Program to alleviate taxpayer burden for violations under the California and
Federal Clean Water Acts. While this does not fall under the purview of DTSC/SCP, we
ask that both work in conjunction with the State Water Resources Control Board to better
protect Californians right to clean water, air and soil.
Only with stringent guardrails can false claims be averted, valid testing results be assured, and
human and environmental health be protected.
CA DTSC has a duty to immediately restrict low-hanging fruit like artificial turf fields where the
science on risk is clear, and the market is replete with vendors of proven alternatives: natural
grass fields.We ask that DTSC/SCP expeditiously bring synthetic turf under the strictest
regulation possible while working with legislators to ban this unnecessary product. States
across the country and in communities up and down California are bringing forth bans,
moratoriums and legislation. Regulatory support is urgently needed.
Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
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Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
4 March 2025: Item #7 - SEQR Discussion, Cornell GFR Hockey Field
Support a full environmental review
Thank you for the opportunity to submit these comments on behalf of Safe Healthy Playing
Fields, Inc (SHPFI).
SHFPI is an all-volunteer 501-c-3 non-profit. We are committed to educating communities,
policy-makers and elected officials about the health, safety and financial realities of plastic fields
versus grass fields and other synthetic surfaces for their parks and schools. Our constituency
ranges from concerned individuals to community and civic organizations, legal, healthcare and
science professionals, municipal leaders and state legislators.
SHPFI is in full support of a GEIS and full SEQR. This project should not be exempt from a full
review of environmental impacts. Despite Cornell University’s word that they will not seek to
install additional synthetic turf on it’s campus, there is no formal obligation that would require
them to stop further installations, except the upcoming New York Carpet EPR Law. They have
not demonstrated transparency, full disclosure, nor a commitment to the safety of students, staff
and visitors who would be exposed to the toxic and carcinogenic chemicals known to exist in
this fossil fuel-based petrochemical plastic product, whether on playing fields or used in
landscaping.1,2
A commitment to not use used tire crumb infill is a distraction meant for all to believe it is the
only concern related to synthetic turf. Often sourced outside of the US, plant based synthetic turf
infills can contain pesticides, PFAS, heavy metals and more. Because they add excess nutrients
to soil and water, they have been implicated in increased frequency and severity of toxic algal
blooms.3,4
4 Royer, Sarah Jeanne (Jan 2023). Choosing Synthetic Turf Is Choosing Environmental Harm. Letter to
Town Council of Glastonbury, CT. Published in Let’s Talk, Talk-Action.org.
https://talk-action.org/choosing-synthetic-turf-is-choosing-environmental-harm/
3 US EPA (1 Feb 2024). Nutrients and Harmful Algal Blooms Research.
https://www.epa.gov/water-research/nutrients-and-harmful-algal-blooms-research
2 Kassotis, C (23 Sep 2024). “Endocrine and cardiometabolic toxicity of artificial turf associated
materials.” Video of presentation at NYU Langone Health symposium on plastics research.
https://www.youtube.com/watch?v=q8MDXyQKnFA
1 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic
toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111),
104562. https://doi.org/10.1016/j.etap.2024.104562
Microplastics:
A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its blades annually. This
estimate is ten times lower than a previous Danish study (0.8 kg/m2). This equates to 2,000 to
3,000 pounds of microplastic blade loss per year per field.5 Newer playing fields that do not
require infill poured on top of the synthetic carpet are more densely woven, may have double
backing,6 and have the potential for significantly greater microplastic blade and carpet backing
loss to the environment.
As calculated by the Martha’s Vineyard Conservancy, a single regulation sized plastic playing
field is the equivalent of 3.2 million plastic bags, or 42 million plastic straws.7
Microplastic synthetic turf blades have been found in Lake Tahoe, where researchers found high
levels of polyethylene and polypropylene in the lake and “…recorded plastics concentrations
more than three times higher than those sampled using a similar method in the North Atlantic
subtropical gyre.”8,9,10
Synthetic turf fibers have been found in the world’s oceans, ranging from 12 to over 15 percent
of the microplastics found, as reported by researchers in Spain, China, Japan, Australia and
Canada. Synthetic turf blades represent as much as 25% of microplastics in surface waters.11
This research lead to the California Coastal Commission's decision to not allow synthetic turf at
UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not superior to natural grass and
is not sustainable.
11 De Haan, WP, Quintana, R, Vilas, C, Cózar, A et al (1 Oct 2023).“The dark side of artificial greening:
Plastic turfs as widespread pollutants of aquatic environments.” Environmental Pollution; 334, 122094.
https://www.sciencedirect.com/science/article/pii/S0269749123010965?via%3Dihub
10 Personal email communication from research staff at Tahoe Environmental Research Center. Lake
Tahoe Email
9 Spencer, C (2023). “Lake Tahoe has higher concentration of microplastics than ocean trash heap.” LA
Times.
https://www.latimes.com/california/story/2023-07-14/lake-tahoe-troubling-concentration-microplastics
8 Schultz, Madison. 2022. “UC Davis Environmental Research Center fundamental at Lake Tahoe.”
Sierra Sun. Accessed 26 Oct 2023.
https://www.sierrasun.com/news/uc-davis-environmental-research-center-fundamental-at-lake-tahoe/
7 Doyle, M, Slavin, D, Thomson, R (29 Jan 2019). “Numbers flawed in turf vs. grass debate.” Martha’s
Vineyard Times.
https://www.mvtimes.com/2019/01/29/numbers-flawed-turf-vs-grass-debate/
6 TenCate Pivot (2024). Face weght of 120 ounces per yard2, double backing, total weight 147.5 ounces
per yard2.
https://geosurfaces.com/wp-content/uploads/2024/05/PIVOT_1.5_Spec-1.pdf
5 Hann, S et al (2018). “Investigating Options for Reducing Releases in the Aquatic Environment of
Microplastics Emitted by (but not Intentionally Added in) Products.” Eunomia, United Kingdom.
https://www.eunomia.co.uk/case_study/measuring-impacts-of-microplastics/
Section 21080.5(d)(2)(A) of CEQA prohibits the Commission from
approving a proposed development if there are feasible alternatives or
feasible mitigation measures available that would substantially lessen any
significant adverse effect which the activity may have on the environment.
For the reasons discussed in this report, the Commission has conditioned
the NOID to require design and implementation of Final Revised Project
Plans that do not include the installation of artificial turf.”12
Additional loss of microplastics from the backing (approximately 438 pounds/per field annually),
exclusive of the underlayment pad and infill.13
Microplastics both leach and adsorb toxic chemicals and bacteria in the environment, putting the
food chain at risk.
13 Kole, PJ, Van Belleghem, F, Stoorvogel, JJ, Ragas, A, Löhr, AJ (10 Dec 2023). “Tire granulate on the
loose: How much escapes turf? A systematic literature review.” Science of The Total Environment;
903)166221.
https://doi.org/10.1016/j.scitotenv.2023.166221
12 California Coastal Commission (13 Dec 2023). “Notice of Impending Development UCS-NOID-0002-23
Baseball Stadium Turf).”
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf
Toxic Chemicals:
As outlined in the 27 Aug 2024 presentation by the California Dept. of Toxic Substances Control
DTSC), there are multiple chemical classes of concern in synthetic turf.14 Some of these
chemicals include (not comprehensive):
PFAS15,16,17,18,19
Phthalates20,21,22
Latex (including styrene butadiene)23,24,25,26
26 Staff writer (3 Jul 2024). “Artificial Turf Fields.” Institute For Climate Change, Environmental Health,
and Exposomics. Mt. Sinai ICAHN School of Medicine.
Exposomic Research
25 Sick, S (2021). Patent
https://patents.justia.com/patent/10968565
24 Sick, S (2017). Patent application
https://patents.justia.com/search?q=FLOOR+PAVEMENT+STRUCTURE+WITH+GEL+L
23 Tomarin, SA (1984). Patent
https://patents.justia.com/patent/4497853
22 IE DuPont de Nemours (2015).
https://patents.justia.com/patent/9017788
21 Safer Consumer Products Program (Aug 2024). “Background Document on Candidate Chemicals in
Artificial Turf.” Dept. of Toxic Substances Control, California Environmental Protection Agency.
https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicals-
in-Artificial-Turf.pdf
20 Ryan-Ndegwa, S, Zamani, R, Martins, T (17 Dec 2024). “Exploring the Human Health Impact of
Artificial Turf Worldwide: A Systematic Review.” Environ Health Insights; (18),11786302241306291
https://doi.org/10.1177/11786302241306291
19 Multi-organizational fact sheet (2022). “PFAS polymers pose serious health and environmental threats.”
https://drive.google.com/file/d/1fJDsNTIPp-YMT_7aQ0TDvTaLg2lB5PMA/view?usp=drivesdk
18 EI DuPont de Nemours (2013)
https://patents.justia.com/patent/8568874
17 Dept. of Toxic Substances Control (27 Aug 2024). “Background Document on Candidate Chemicals in
Artificial Turf.” California EPA.
https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicals-
in-Artificial-Turf.pdf
16 Woelke, D (Nov 2024). Compilation of PFAS leachate testing from synthetic turf results.
PFAS leachate from synthetic turf
15 Glüge, J, Scheringer, M, Cousins, IA, DeWitt, JC et al (30 Oct 2020). “An overview of the uses of per-
and polyfluoroalkyl substances (PFAS).” Environ Sci Process Impacts;22(12):2345–2373.
https://pmc.ncbi.nlm.nih.gov/articles/PMC7784712/
14 Dept. of Toxic Substances Control. (27 Aug 2024). California EPA.
Presentation Slides
Polyvinyl chloride27,28,29
Naptha18,,30,31
Siloxanes32,33
Talc34,35
Di/Isocyanates36
Formaldehyde29
Fungicides26
Flame retardants26
Coal fly ash26
Anti-Microbial agents37,38,39
39 Verdú, I, Gonzalez-Pleiter, M, Leganés, F et al (Mar 2021). “Microplastics can act as vector of the
biocide triclosan exerting damage to freshwater microalgae.” Chemosphere.
https://www.sciencedirect.com/science/article/abs/pii/S0045653520333907
38 Triclosan Fact Sheet. BioMonitoring California.
https://biomonitoring.ca.gov/sites/default/files/downloads/TriclosanFactSheet.pdf
37 Dow Chemical (2017).
https://patents.justia.com/patent/20190078235
36 Sick, S (2021) patent
https://patents.justia.com/patent/11180894
35 Dow Global Technologies, Inc (2008) patent application
https://patents.justia.com/patent/20100279032
34 Sick, S (2015) patent
https://patents.justia.com/patent/10968565
33 Dow Global Technologies, Inc (2015) patent
https://patents.justia.com/patent/9040627
32 Ferreira T, Homem V, Cereceda-Balic F et al (2024). “Are volatile methylsiloxanes in downcycled tire
microplastics? Levels and human exposure estimation in synthetic turf football fields.” Environ Sci Pollut
Res Int. 10.1007/s11356-024-31832-1
https://link.springer.com/article/10.1007/s11356-024-31832-1
31 Modern Fibers Inc (1984) patent
https://patents.justia.com/patent/4617208
30 Sick, S (2017) patent application
https://patents.justia.com/patent/8568874
29 Hayes, GE (2010).
https://patents.justia.com/patent/7838096
28 J. F. Adolff AG (1977) patent
https://patents.justia.com/patent/4007307
27 DOC Sports Surfaces (2008) patent application
https://patents.google.com/patent/US7838096B2/en?oq=7838096
Dibutyltin Ethylene glycol40
UV stabilizers30,41.42
Anti-Static Treatments30
Colorants
All synthetic turf tested by academic institutions and independent third party laboratories using
proper methods, techniques and reporting limits have found PFAS in synthetic turf.43,44
Impervious surfacing:
Synthetic turf is an impervious, or impermeable, surface, despite what the industry tells you.
The US EPA and the State of California are clear on this issue:45
areas such as gravel roads...that will be compacted through design or use to reduce
their impermeability.” It further has defined impervious surfaces as…[a]ny surface that
prevents or significantly impedes the infiltration of water into the underlying soil. This can
include but is not limited to: roads, driveways, parking areas and other areas created
using non porous material; buildings, rooftops, structures, artificial turf and compacted
gravel or soil.”
Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until
runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into
stormwater drains and directly to local water bodies. As impervious surfaces increase,
stormwater runoff increases in quantity, speed, temperature, and pollutant load. When
impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and
continues to increase until, at 100% impervious surface coverage, runoff is five times
45 US EPA, MS4 General Permit Appendix A, Definitions, Abbreviations and Acronyms,
https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-a-2016-ma-sms4-gp.pdf
44 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf:
Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of
Massachusetts, Lowell.
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2
0Other%20Tests%20Aug%202024_tcm18-386957.pdf
43 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive
Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University
of Notre Dame.
https://doi.org/10.7274/bg257d30j3m
42 Awonaike, B, Lei, YD, Parajulee, A, Wania, F (1 Dec 2021). “Phase partitioning, transport and sources
of Benzotriazole Ultraviolet Stabilizers during a runoff event.” Water Research X; (13),100115
https://www.sciencedirect.com/science/article/pii/S2589914721000281#:~:text=High%20levels%20of%20
UV328%20and%20UV234%20were,a%20sink%20than%20a%20source%20of%20BT%2DUVs
41 International Pollutant Elimination Network.“Communications on Recent Research: Recent Research
on UV-328 Further Proves its Potential to Undergo Long-Range Transport, Bioaccumulate, and Cause
Harm.”
https://ipen.org/sites/default/files/documents/ipen-uv328-research-update-v1_2-en.pdf
40 Sick (2017)
https://patents.google.com/patent/WO2018122346A1
that of a forested watershed. Excessive stormwater runoff also increases the potential
for flooding.” US EPA Impervious Surface Fact Sheet46
As impervious surfaces, accumulation of particulate matter, jet and leaded AVgas fuel from the
multiple flight paths that border Cornell’s campus bring even more need for concern.
In 2023, Ithaca had 39.5 inches of rainfall and 42.5 inches of snowfall. In 2024, the totals were
36.5 inches and 35.3 inches respectively. Toxic runoff from synthetic turf contributes 27,000
gallons per one inch of rain per acre of plastic.47 One inch of snowfall is roughly equivalent to 13
inches of rain.48 It is abundantly clear that, given the amount of synthetic turf currently installed
on Cornell’s campus, that a massive amount of toxic runoff from synthetic fields is contaminating
soil, surface, ground and, eventually, the campus and town’s drinking water.
48 NOAA National Severe Storms Laboratory. (n.d.). Winter Weather FAQ.
https://www.nssl.noaa.gov/education/svrwx101/winter/faq/
47 Cotrone, V (undated). “The Role of Trees and Forests in Healthy Watersheds: Managing stormwater,
reducing flooding, and improving water quality.” Penn State Extension.
https://extension.psu.edu/the-role-of-trees-and-forests-in-healthy-watersheds
46 US EPA (2020). “EnviroAtlas: Fact Sheet, Percent Impervious Area.”
https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/ESN/PercentImperviousArea.pdf
Greenhouse Gasses:
Synthetic turf off-gasses both methane and ethylene49,50 and continues day and night, in ever
increasing amounts for the 1,000 years it takes for it to decompose.51 Methane traps 90% more
heat than carbon dioxide and is 21 times more potent. Land based plastics produce 2 times
more methane and 76 times more ethylene than plastics found in waterways and oceans.
The heat islands created by plastic turf playing fields are large enough to be visible from
satellites circling our planet. Even if all synthetic turf were removed from Los Angeles today,
methane would linger in the atmosphere for approximately 12 years, contributing to climate
change and sea level rise for hundreds of years after pollutants have been cleared from the
air.52
A 2017 Swedish study of total life cycle emissions on a modeled 7881m2 synthetic field
concluded GHG emissions would be 527 tons of CO2e for a ten year use period, exclusive of
manufacturing, transport, construction, removal and disposal.53
The Lawrence Berkeley National Laboratory released a report in April 2024 finding that the
greenhouse emissions from plastics is four times those emitted by the aviation industry.54
54 Karali, N, Khanna, N, Shah, N (12 Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence
Berkeley National Laboratory Publications.
https://escholarship.org/uc/item/12s624vf
53 Magnusson, Simon, Mácsik, Josef (July 2017.. Analysis of Energy Use and Emissions of Greenhouse
Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf. Resources,
Conservation and Recycling Vol. 122, July 2017, Pages 362-372
https://doi.org/10.1016/j.resconrec.2017.03.007
52 National Oceanic and Atmospheric Administration. “Methane.”
https://climate.nasa.gov/vital-signs/methane/?intent=121
51 Chamas, A, Moon, H, Zheng, J (3 Feb 2020). “Degradation Rates of Plastics in the Environment.”
ACS Sustainable Chemistry & Engineering;(8)9.b
https://pubs.acs.org/doi/10.1021/acssuschemeng.9b06635
50 Royer, SJ (12 Nov 2018). Letter to Mayor M Bowser, Washington DC regarding synthetic turf.
Letter to Mayor M Bowser
49 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic
in the Environment.” PlosOne 13(8): e0200574.
https://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0200574&type=printable
The resulting impact on climate change from plastics and synthetic turf are contributing factors
to increased flood risk and toxic runoff55; toxic exposures during wildfires56,57; and escalating
insurance costs due to both.58,59,60 The most profoundly impacted will be those who can least
afford the increased burdens.
60 Capani, C (7 May 2024). “Aviva issues flood risk warning as residents turn to artificial lawns.”
Insurance Times; United Kingdom.
https://www.insurancetimes.co.uk/news/aviva-issues-flood-risk-warning-as-residents-turn-to-artificial-lawn
s/1451833.article
59 Sherriff, L (18 Mar 2024). “Climate change is fuelling the US insurance problem.” British
Broadcasting Corp.
https://www.bbc.com/future/article/20240311-why-climate-change-is-making-the-us-uninsurable
58 Mandel, A, Battiston, S, Monasterolo, I. (5 Feb 2025). “Mapping global financial risks under climate
change. Nature, Climate Change.
https://doi.org/10.1038/s41558-025-02244-x
57 Staff writer (17 Jan 2025). “Plastic Chemicals in Wildfire Smoke and How to Protect Yourself.” Plastic Soup
Coalition.
https://www.plasticpollutioncoalition.org/blog/2025/1/17/plastic-chemicals-in-wildfire-smoke-and-how-to-pr
otect-yourself
56 Schlanger, Z (15 Jan 2025). “What Happens When a Plastic City Burns.” The Atlantic.
https://www.theatlantic.com/science/archive/2025/01/los-angeles-fire-smoke-plastic-toxic/681318/
55 Simpson, TJ, Francis, RA (Aug 2021). “Artificial lawns exhibit increased runoff and decreased water
retention compared to living lawns following controlled rainfall experiments.” Urban Forestry & Urban
Greening; (63), 127232
https://www.sciencedirect.com/science/article/abs/pii/S1618866721002570
Not recyclable:
Less than 6% of plastics are recycled.61 Made of mixed plastics, synthetic turf is not recyclable,
not sustainable and is a linear, not a circular product, and does not meet any definition of
sustainability. The synthetic turf industry misrepresents its products when they make claims
related to sustainability and environmentally friendliness. It is not enough to use the vernacular
of the day.
Circular products62 are “…those products that have reduced or completely no need for virgin
resources and are designed with the end of their life in mind.”
The United Nations defines sustainable development63 as “development that meets the needs of
the present without compromising the ability of future generations to meet their own needs.”
The UCLA Sustainability Committee64 notes: “In simplest terms, sustainability is about our
children and our grandchildren, and the world we will leave them”.
The Rutgers Center for Sustainable Materials65 definition:
Sustainable materials are materials used throughout our consumer and industrial
economy that can be produced in required volumes without depleting non-renewable
resources and without disrupting the established steady-state equilibrium of the
environment and key natural resource systems.”
TenCate’s “recycling” facilities:
65 Rutgers University. “What are Sustainable Materials?” Department of Materials Science and
Engineering, Center for Sustainable Materials. Accessed 26 Jan 2025.
https://mse.rutgers.edu/center-sustainable-materials
64 UCLA Sustainability Committe, quoting UN World Commission on Environment and Development
https://www.sustain.ucla.edu/what-is-sustainability/
63 United Nations (2024). “Sustainable Development Agenda: What is sustainable development?”
https://www.un.org/sustainabledevelopment/development-agenda/#1b1981a30bdd8fde2
62 “What is a circular product?” Circular Tayside, United Kingdom.
https://circulartayside.co.uk/what-is-a-circular-product-and-business-model/
61 Dell, J, Enck, J (May 2022). “The Real Truth about the US Plastic Recycling Rate.” Beyond Plastics.
https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/62b2238152acae761414d698/1655
841666913/The-Real-Truth-about-the-US-Plastic-Recycling-Rate-2021-Facts-and-Figures-_5-4-22.pdf
Louisiana-
California-
Separate property Leased property R center of image
SHPFI urges you to not support Cornell University’s false environmental claims. Demand
excellence. Demand a full environmental review. Do not kick the can down the road to future
generations to clean up the environmental mess the University knowingly and willfully seeks to
impose without full disclosure or transparency. This is your environment, your health that you
are putting at risk and imposing on your children, and their children’s children.
Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
STATE OF NEW YORK
SUPREME COURT: COUNTY OF TOMPKINS
ZERO WASTE ITHACA,
Petitioner
v.
ITHACA CITY PLANNING &
DEVELOPMENT BOARD AND CORNELL
UNIVERSITY
Respondents
Index No.: EF2024-0816
Justice Mark G. Masler
REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT
OF VERIFIED AMENDED PETITION
Todd D. Ommen
Julianne Frey
Attorneys for Plaintiff
PACE ENVIRONMENTAL LITIGATION
CLINIC, INC.
78 North Broadway
White Plains, New York 10603
Phone: (914) 422-4343
Fax: (914) 422- 4433
CI2025-03769 Index # : EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
1 of 17
TABLE OF CONTENTS
PRELIMINARY STATEMENT ...........................................................................................1
ARGUMENT .........................................................................................................................2
1. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED
THE BECAUSE THE ZWI MEMBERS HAVE STANDING TO BRING THIS
LAWSUIT ...............................................................................................................2
A. Petitioner Effectively Alleged Injuries Different from Those of The
General Public ................................................................................................2
B. Regardless of Whether or Not the Property is Private, There is Still an
Ability to Challenge the Planning Board’s SEQRA Decision .......................5
C. ZWI Has Always Had Standing to Bring This Petition .................................6
2. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE
PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK
REVIEW” AS REQUIRED BY STATUTE, AND THE NEGATIVE
DECLARATION IS ARBITRARY AND CAPRICIOUS. ......................................7
A. The Standard of Review Under SEQRA is A Hard Look Review ................7
1. PFAS ...............................................................................................8
2. Microplastic Shedding ....................................................................10
3. Air Emissions and VOCs ................................................................10
B. The Negative Declaration relies on the Respondent’s Future Actions
making it Conditional ....................................................................................11
CONCLUSION ......................................................................................................................12
CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT ....................12
CI2025-03769 Index #: EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
2 of 17
ii
TABLE OF AUTHORITIES
Cases
Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating,
849 N.Y.S.2d 112 (3d Dep’t 2007) ................................................................................... 3
Cannon v. Murphy,
600 N.Y.S.2d 965 (2d Dep’t 1993) ................................................................................... 11
Elizabeth Street Garden, Inc v. City of New York,
42 N.Y.3d 992 (2024) ...................................................................................................... 2, 7
Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton,
613 N.Y.S.2d 257 (2d Dep’t 1994) .................................................................................. 11
Heritage Coal. v. City of Ithaca Planning and Dev. Bd.,
644 N.Y.S.2d 374 (3d Dep’t 1996) ................................................................................... 4, 5
Jackson v. New York State Urban Dev. Corp.,
67 N.Y.2d 400 (1986) ....................................................................................................... 7
Merton v. McNally,
90 N.Y.2d 742 (1995) ....................................................................................................... 11
New York City Coal. for the Preserv. of Gardens v. Giuliani,
666 N.Y.S.2d 918 (1st Dep’t 1998) .................................................................................. 3
Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency,
720 N.Y.S.2d 768 (Sup. Ct. Westchester Cnty. 2001)...................................................... 6
Saratoga Lake Prot. v. Dep’t of Public Works,
846 N.Y.S.2d 786 (3d Dep’t 2007) ................................................................................... 3
Save Pine Bush, Inc. v. Common Council of City of Albany,
13 N.Y.3d 297 (2009) ....................................................................................................... 1
Save the Pine Bush, Inc. v. Town of Guilderland,
168 N.Y.S.3d 561 (3d Dep’t 2022) ................................................................................... 6
Save Our Main St. Bldgs. v. Greene County Legis.,
740 N.Y.S.2d 715 (3d Dep’t 2002) ................................................................................... 4
Seneca Lake Guardian v. New York State Dep’t Env’t Conserv,
216 N.Y.S.3d 78 (3d Dep’t 2024) ..................................................................................... 6
Shapiro v. Torres,
60 N.Y.S.3d 366 (2d Dep’t 2017) ..................................................................................... 2
W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown,
861 N.Y.S.2d 864, 866 (3d Dep’t 2008) ........................................................................... 9, 11
Rules
N.Y. CPLR Rule 1025 (McKinney 2000) .............................................................................. 6
CI2025-03769 Index #: EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
3 of 17
iii
Regulations
6 NYCRR § 617.7(b) .............................................................................................................. 7
N.Y. Env’t Conserv. Law §8-0101 ......................................................................................... 7
N.Y. Env’t Conserv. Law §8-0109 ......................................................................................... 7
N.Y. Env’t Conserv. Law §27-3313 (2) ................................................................................. 9
CI2025-03769 Index #: EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
4 of 17
1
PRELIMINARY STATEMENT
Petitioner Zero Waste Ithaca (“ZWI”) respectfully submits this Reply memorandum in
further support of its Amended Petition challenging Respondent Ithaca Planning and
Development Board’s (the “Planning Board”) arbitrary and capricious finding under the State
Environmental Quality Review Act (“SEQRA”) that Respondent Cornell University’s
collectively with the Planning Board, “Respondents”) use of artificial turf fields will have no
possible significant adverse environmental impact (the “Negative Declaration”). The Planning
Board’s failure to order an Environmental Impact Statement (“EIS”) violates SEQRA’s
fundamental purpose: investigating and mitigating environmental harm before it occurs. ZWI
brings this petition because its members—who regularly work, study, and engage on Cornell's
campus and community—will be directly harmed by the disregard for public health and
environmental responsibility.
Rather than focusing on defending the Negative Declaration on the merits, Respondents
initially allege that ZWI has no standing to bring this suit. Respondents first argue that ZWI’s
members suffer no particularized harm from the Negative Declaration, but this contention
ignores that, unlike the public at large, ZWI’s members rwork, study, and engage with Cornell’s
campus every day. ZWI has demonstrated that its members would suffer harm different from that
of the general public including the degradation and recreational, environmental and aesthetic
interests in nature and green space. Save Pine Bush, Inc. v. Common Council of City of Albany,
13 N.Y.3d 297, 304 (2009). Moreover, ZWI had the ability to bring suit as an unincorporated
association, but even if this were a defect, that defect has now been rendered moot by ZWI’s
incorporation.
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Similarly, Respondents’ assertion of a proper “hard look” review of the potential
environmental impacts and the finding of no significant adverse environmental impacts largely
ignores the extensive record in this matter. The fact that Respondents can point to a handful of
papers or studies that at least in part support their position does not establish that there will be no
possibility of any adverse environmental impact, as required by SEQRA. Elizabeth Street
Garden, Inc v. City of New York, 42 N.Y.3d 992, 995 (2024). Absent such a showing, where, as
here, there is ample research and analysis showing potential impacts, the only legal path was for
Respodents to complete an EIS. Citing only a handful of studies—while disregarding a
substantial body of research demonstrating potential harm—does not satisfy SEQRA’s “hard
look” requirement.
ARGUMENT
I. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED
BECAUSE THE ZWI MEMBERS CAN ESTABLISH STANDING TO BRING
THIS LAWSUIT.
Respondents assert that Petitioner lacks standing because its members do not suffer an
injury different from the general public, that the members cannot access the project site, and
ZWI’s unincorporated status at the time the Petition was filed. Each of these contentions fails
after review of the record and circumstances of this dispute, as well as developments since the
filing of the Petition.
A. Petitioner Sufficiently Established Injuries Different from Those of the General
Public.
To establish standing under SEQRA, a petitioner must demonstrate an environmental
injury different from the general public and that the alleged injury falls within the scope of
interests being protected by SEQRA. Shapiro v. Torres, 60 N.Y.S.3d 366, 368 (2d Dep’t 2017).
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The offices of ZWI member Emily Jernigan, a Cornell University full-time staff member and
Amina Mohamed, a Ph.D. candidate in Ecology and Evolutionary Biology, are located very near
the proposed project site. Respondent asserts that their offices, 560 feet and 265 feet away from
the project site, respectively, are too far away from the site to establish standing. (NYSCEF Doc.
No. 43, pp 11.). Referencing New York City Coal. for the Preserv. of Gardens v. Giuliani,
Respondents compare these facts, two community members of a private institution as similar to
trespassers who had established a community garden on a vacant lot. 666 N.Y.S.2d 918, 918-19
1st Dep’t 1998) aff’g 670 N.Y.S.2d 657, 659 (Court dismissed a SEQRA petition on standing
grounds as petitioners did not have any legal right to the garden). Ms. Jernigan and Mohamed did
not use the field as it is restricted to athletics, and ZWI does not contend that the project site is
available to them. But, notwithstanding that the field may be off limits to non-athletes, proximity
can still establish standing. As Cornell community members, ZWI members must be in the
vicinity for work and study and have an interest in and enjoy the natural environment. That
environmental is what is threated by the PFAS, microplastics and other toxins that would be
released by the proposed field, as set forth in the Amended Petition. Indeed, proximity
established by ZWI’s affiants is well within the range of that found sufficient for SEQRA
standing. The Third Department has previously held that proximity within 1,000 feet of a
development site can be sufficient to establish. See, Saratoga Lake Prot. v. Dep’t of Public
Works, 846 N.Y.S.2d 786, 791 (3d Dep’t 2007) (petitioners demonstrated standing from 1,000
feet of development); Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849
N.Y.S.2d 112, 115 (3d Dep’t 2007) (petitioner alleged an injury differentiated from that of the
general public because her residence was 941 feet away from the proposed project and identified
an environmental concern arising from that proximity). Ms. Jernigan and Mohamed’s offices are
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located much closer, within 560 and 265 feet of the project site, well within a distance sufficient
for standing (NYSCEF Doc. No. 43, memorandum of law in support denying petition at 11).
Respondents further argue that even if their offices were not too far removed, the campus
has ample green spaces for the Petitioners to enjoy and interact with nature. (NYSCEF Doc. No.
43 at 16-17). But this argument entirely misses the point of SEQRA, which is to protect the site
at issue. Ms. Mohamed said she often takes breaks in the area of the field. (NYSCEF Doc. No.
11, affirmation of Amina Mohamed at 2). The existence of other green spaces is simply
irrelevant. First, those neighboring green spaces are exactly what would be impacted by the
toxins emanating from the field, as multiple studies submitted to Respondents demonstrate. In
any event, SEQRA does not permit the degradation of one green space simply because other
green spaces may exist nearby. Ms. Mohamed does not allege to take breaks elsewhere; she takes
breaks around the project site. (Id.) The area she frequents, close to her office, the subject of this
petition – not other green spaces.
Respondents correctly state that proximity alone is not always enough to confer standing.
Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715, 717-18 (3d Dep’t 2002).
However, the matter here is substantially different from Save Our Main St. Bldgs., where the
petitioners did not allege any unique environmental injuries. Save Our Main St. Bldgs., 293
A.D.2d at 909 (petitioners alleged increased traffic concerns, one concerned about more traffic
for their store on the main street, noise complaints, an aesthetic injury despite the project not
being visible as it was on the same side of the street as petitioner’s store, and a petitioner who
was concerned about educational walks through a public main street.) Respondents’ reliance on
Heritage Coal. v. City of Ithaca Planning and Dev. Bd., to demonstrate as another example of
how the appreciation of a building, Cornell’s Sage Hall, was not enough of an injury, is
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misplaced. 644 N.Y.S.2d 374, 376-377 (3d Dep’t 1996) (dismissal of a SEQRA petition based
on standing; three educators failed to show how their injury was different from that of the
general public.) Heritage Coal. is distinguishable from the present matter because of the goals of
SEQRA; “...the diminution of [their] appreciation of Sage Hall and [their] use of it as a teaching
tool, is not, without more, within the zone of interest sought to be promoted or protected by
either SEQRA…” Id. at 376. In contrast, there can be no question that the environmental injuries
alleged here – environmental contamination from PFAS, micro plastics and other toxins – are
within the zone of interests of SEQRA.
ZWI members demonstrate unique environmental harms congruent with the SEQRA’s
aims and further allege a much closer connection to Cornell’s campus than the public at large.
See, N.Y. Envtl. Conserv. Law §8-101. Ms. Jernigan and Mohamed, by virtue of their proximity,
interests in the natural state of the campus, members of the faculty and staff, and Ms.
Mohamed’s breaks in the areas, establish harm greater than that of the general public.
B. Regardless of Whether the Property is Private, Petitioner Can Still Challenge
The Planning Board’s SEQRA Decision.
Respondents’ next argument focuses on the project site functioning as an athletics field
that is only accessible to authorized students; therefore, Respondents argue, ZWI members could
not have standing for a field they cannot enter the field. NYSCEF Doc. No. 43, 16-17. Case law
does not indicate that Petitioners must have access to the site to sustain an injury from a site’s
development. It is not and cannot be the law that development on a privately owned site is
immune from SEQRA challenges. Indeed, as discussed below, development will often naturally
occur on private property, and courts have found proper standing for environmental groups
nevertheless.
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The Petitioner’s standing should be considered within the entire scope of the facts. The
fact that the field may be, in a sense, “private” does not mean that those in proximity cannot have
standing. If it were otherwise, nobody would ever have standing to challenge development on
private property, which would eviscerate the purpose of SEQRA. To the contrary, the mere fact
that a standing witness does not have legal access to a property does not defeat standing. Indeed,
recently the Third Department held just that. In Save the Pine Bush, Inc. v. Town of Guilderland,
168 N.Y.S.3d 561, 566 (3d Dep’t 2022), the court held that an environmental group had standing
to challenge a development on private property due to the group’s interests in the surrounding
environment. See also, Seneca Lake Guardian v. New York State Dep’t of Env’t Conserv., 216
N.Y.S.3d 78, 81 (3d Dep’t 2014) (where the dumping of leachate into a water body not owned
by the plaintiff, found successful standing).
C. ZWI Has Always Had the Legal Ability to Bring This Petition, and Now Has
Been Incorporated.
Finally, Respondents’ argument that ZWI lack the capacity to sue was incorrect and, in
any event, is now moot, as ZWI is no longer an unincorporated entity. New York does allow
unincorporated organizations to bring legal actions, pursuant to the CPLR § 1025, which
provides that “[an action] may be brought by or against the president or treasurer of an
unincorporated association on behalf of the association in accordance with the provisions of the
general associations law.” While Ms. Koizumi, the founder of ZWI, may not be explicitly listed
as the organization's “president,” she functions and operates as such, performing the “equivalent
functions and responsibilities” of a small grassroots organization by advocating for change and
informing the public of potential risks. Pelham Council of Governing Bds. v. City of Mount
Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768, 770 (Sup. Ct. Westchester Cnty. 2001) (provides
that an unincorporated organization may proceed in a lawsuit if they function like a treasurer or
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president of an organization); see, NYSCEF Doc. No. 18 at pp 5 (demonstrating Ms. Koizumi’s
advocacy.) Additionally, the Respondent’s arguments about undertakings are entirely irrelevant,
as there has not been a preliminary injunction at this point and the issue of an undertaking is not
before the Court. NYSCEF Doc. No. 43 at 20.
In all events, the argument is now moot. As of January 27, 2025, ZWI is recognized by
New York State as a not-for-profit corporation. (See Affirmation of Yayoi Kozumi, submitted
herewith.)
II. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE
PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK”
AS REQUIRED BY STATUTE.
A. The Standard of Review Under SEQRA is A Hard Look Review.
ZWI will suffer tangible environmental harms from the planning board’s negative
declaration that the project will not have any potential adverse environmental impacts. (6
NYCRR § 617.7(b) (emphasis added)). SEQRA aims to “...encourage productive and enjoyable
harmony between man and his environment; to promote efforts which will prevent or eliminate
environmental damage and enhance human and community resources…” N.Y. Envtl. Conserv.
Law § 8-0101. To accomplish these goals, applicants must complete an environmental
assessment form (EAF) to determine when a longer, more in-depth environmental assessment, an
EIS, is necessary. Id. at § 8-0109. The determination of whether to complete an EIS must be
based on the agency (here the Planning Board) taking a “hard look” at all potential impacts. A
hard look” review is when “the lead agency [identifies] the relevant areas of environmental
concern, [takes] a ‘hard look’ and [makes] a reasoned elaboration’ on the basis for its decision.”
Elizabeth Street Garden, 42 N.Y.3d at 994 (2024) (omitting internal quotations); see, Jackson v.
New York State Urban Dev. Corp., 67 N.Y.2d 400, 417 (1986.) If, after taking that “hard look,”
there are any potential adverse impacts, an EIS is the only permissible next step under SEQRA.
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Put another way, where the material before the reviewing agency indicates that there is
any potential for a significant impact, the agency cannot rationally determine that the project will
not have a significant adverse impact on the environment. Elizabeth Street Garden, 42 N.Y.3d at
994. Respondents assert that the “multiple hours” spent at planning board meetings, reviewing
documents, and asking some questions was enough to counter the numerous contradicting
information and studies and glaring biases from fact gatherers the planning board relied on.
NYSCEF Doc. No. 43 at 24-25, 21). But the amount of time is not the question here; rather, the
question for this Court is whether that record revealed any potential impacts. The quantity of
time spent on an issue is not an indication that the Planning Board had a substantive review of
possible adverse environmental impacts. The mere fact there were 70 pages of citations to
contradictory studies presented to the Planning Board should have triggered an EIS as it indicates
at a minimum – an open question as to environmental impacts. NYSCEF Doc. No. 18 at pp 5
One organization’s, ZWI’s, submissions to the Planning Board for consideration.)
1. PFAS
Respondents have asserted time and time again that the science proving that artificial turf
fields is sound, going so far as saying that “[o]ver 100 scientific, peer reviewed, published
studies have been performed worldwide evaluating the potential health risks with turf fields that
use crumb rubber. We are not aware of any peer reviewed scientific studies that draw an
association between adverse health effects and use of crumb rubber.” NYSCEF Dos. No. 43 at 4.
It is again repeated that the PFAS concerns are not serious. Id. at 20 (Respondent states that they
have “rebutted” the claims). The question of health impacts is certainly relevant, but an EIS is
triggered under SEQRA by any significant adverse environmental impact, not just human health
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impacts. Petitioner was not required to prove medical causation to trigger an EIS. Potential
environmental impacts were obvious from the submissions to the Planning Board.
The bibliography provided to the Planning Board has several relevant studies affirming
synthetic turf is a concern. See generally, Bibliography NYSCEF Doc. No. 20. Similarly, though
the Respondents have stated that over 100 scientific and peer reviewed studies claim that there
are not adverse health effects linked to the use of crumb rubber, Respondents only cite to six. R.
0641-42. While Respondent’s insist that their own submitted documentation proved more
compelling to the Planning Board, that PFAS would not be a significant concern, Respondent’s
seemed to contradict their statement earlier in their memo that PFAS contamination is pervasive
already. NYSCEF Doc. No. 43 at 20, 4 (respondents allege their own material is persuasive
enough to the planning board that PFAS concerns are unimportant but suggest in their statement
of the facts their summary suggests that because PFAS are already pervasive in the environment
the amount from synthetic turf won’t be significant). Arguing that contamination is already
present should not and does not establish no possible environmental impacts.
Respondents also assert that because they modified their project to comply with a new
New York state ban on carpet containing PFAS, including synthetic turf, going into effect in
2026, the Planning Board was entitled to defer to Cornell’s compliance with applicable law when
issuing a negative declaration. N.Y. Env’t Conserv. Law §27-3313 (2). However, the ban going
into effect is further evidence that the Planning Board’s negative declaration decision was
arbitrary and capricious; environmental risks are associated, which is why there is a ban going
into effect in the near future. Id. There is a recognized environmental threat substantial enough to
warrant a statewide ban, this should not be ignored under SEQRA. Likewise, the case law
Respondents rely on to ameliorate concerns hinges on having already completed a
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comprehensive EIS. W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of
Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008). This is all Petitioner here seeks:
completion of an EIS to examine these open issues.
2. Microplastic Shedding
Respondents assert that they have “submitted extensive documentation from scientific
studies” about microplastics. NYSCEF Doc. No. 43. at p. 21. However, this is misleading as the
record indicates that one letter, from the Respondent’s employee Dr. Frank Rossi, addressed
microplastics. R. 0622-23. The content of Dr. Rossi’s letter focused primarily on the necessity of
a synthetic turf field and the alleged adequacy of a microplastic filter. Id. The letter only
referenced one scientific study, and it did not name it. Id. This one reference without citing a
relevant study is in stark contrast from the alleged extensive documentation. ZWI submitted
several studies from credible environmental journals and other sources explaining the risks of
microplastics entering the environment. NYSCEF Doc. No. 20 at 33. ZWI submitted information
from at least two scientific studies, Chand et al., 2024 and Park et al., 2022, demonstrating that
the proposed stormwater filter, added to mitigate plastic pollution in runoff, would not be
sufficient as the plastic degrades and becomes smaller than the 212-micron pore size of the filter,
leading to plastic pollution and contamination in waterways. R. 1425.
In this same vein, the EPA in 2024 documented that the majority of people who had used
synthetic turf fields would have find the fill on their person, in their cars and in their homes after
the fact (R.1700) demonstrating the difficulty and confirming that synthetic turf users routinely
carry microplastics on their skin, shoes, and clothing, dispersing them into homes, cars, and
water systems.
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3. Air Emissions and VOCs
Despite the Respondent’s contentions, the record lacks scientific studies showing a
consensus that emissions and VOCs from synthetic turf fields have no health impacts. Initially,
as noted above, Petitioner was not required to show health impacts – rather, environmental
impacts are the question. In any event, Respondents cite to a 2018 Guidance Document from the
New York State Department of Health quoting that the exposures to VOCs, SVOCs and airborne
particulate matter was insignificant and not unlike the exposure a person would have on a natural
turf field. NYSCEF Doc. No. 43 at 21-22. Respondents failed to include the part of the quote that
says when the synthetic field is not exposed to open air, when “collected from an indoor
synthetic turf field [air samples] had higher concentrations [of VOCs, SVOCs and airborne
particulate matter] than the outside fields.” R. 3152. The earlier 2018 study in complete context
corroborates the recent findings from a 2023, among many others, that microplastic inhalation is
a confined indoor space is an elevated risk due to microplastic’s small size and density
compounded with their ability to stay in the space due to a lack of air circulation. R.1426. ZWI
raised several other concerns about air borne microplastics and environmentally persistent free
radicals from reputable academic sources, the Center for International Environmental Law and
Huang et al., 2022, that went unaddressed. Id.
B. The Negative Declaration relies on the Respondent’s Future Actions making it
Conditional
The insufficient detail provided in the negative declaration reasoning, despite the variety
of potential environmental impacts, means the Planning Board's issuance of the negative
declaration violated SEQRA. See, Farrington Close Condominium Bd. of Managers v. Incorp.
Vill. of Southampton, 613 N.Y.S.2d 257, 259 (2d Dept 1994); Cannon v. Murphy, 600 N.Y.S.2d
965, 968 (2d Dept 1993).
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The Planning Board's reliance on future actions and mitigation measures as justification
for foregoing an EIS is impermissible. The cases the Respondents point to, W. Beekmantown
Neigh. Ass’n Inc and Merton v. McNally, are fundamentally different in the extent of their
mitigation. W. Beekmantown Neigh. Ass’n Inc, 861 N.Y.S.2d at 866 (mitigation after an EIS had
already been done did not require another EIS); Merton v. McNally, 90 N.Y.2d 742, 755 (1995)
mitigation entailed adding an additional 2 feet of buffer space).
Ultimately the planning board’s decision was not merely arbitrary and capricious given
the record but also patently wrong about the facts. It is established that it is not for this Court to
determine the whether the planning board’s reasoning for a negative declaration is adequate, it is
within the scope to determine if it complied with SEQRA requirements in finding no potential
significant impact. Here, due to its failure to adequately assess key issues in the record, the
Planning Board plainly did not comply.
CONCLUSION
For the reasons outlined above, Petitioners respectfully request that this court maintain
allow our petition to go forward.
Dated: February 13, 2025
White Plains, NY
Respectfully submitted,
Todd D. Ommen
Pace Environmental Litigation Clinic, Inc.
78 North Broadway
White Plains, NY 10603
914) 422-4343
tommen@law.pace.edu
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CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT
The undersigned attorney hereby certifies:
This document complies with the word count limitations pursuant to Rule 202.8-b (c) of
the Uniform Civil Rules for the Supreme Court and the County Court as amended by the
Administrative Order 270-20, effective February 1, 2021. According to the word processing
system used in this office, this document, exclusive of the sections excluded by Rule 202.8-b (b),
contains 3,595 words.
Dated: February 13, 2025
Todd D. Ommen
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From:
To:
Cc:
Subject:
Sent:
Sheila Out
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Field Hockey Turf on Game Farm Road Site
3/17/2025 1:56:07 PM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Planning Board Members,
I'm an Ithaca resident who has grave concerns about this and related projects. One of my
concerns is the danger of the microplastics that will result from these projects. I strongly
urge you to require a GEIS for the entire Game Farm Road site.
Sincerely,
Sheila Out
247 Valley Rd
Ithaca
From:
To:
Cc:
Subject:
Sent:
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Larri Richmond
Town Of Ithaca Planning
pbstaff@cityofithaca.org; info@zerowasteithaca.org;
Field turf
3/17/2025 7:50:17 PM
Dear Town Planning Board Members,
The August 2024 report from the University of Massachusetts Lowell confirms
that PFAS have been detected in all components of artificial turf, including
blades, backing, infill, shock pads, adhesives, and even product packaging. Despite
Cornell University’s claims that its field hockey turf is different because it lacks infill,
this report demonstrates that PFAS contamination is not limited to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO
materials. However, this study, conducted by a respected research center with full
citations and expert analysis, is highly relevant to the town planning board’s review.
Declaring a negative declaration without considering this research is a failure of due
diligence. It is also deeply problematic that Cornell seeks to control the narrative by
discounting high-quality investigative journalism and research from credible
organizations—especially in a rapidly evolving field where new findings emerge
constantly.
Additionally, some artificial turf manufacturers have marketed their products as
PFAS-free,” but testing in this report reveals PFAS were still found in those materials.
This raises serious concerns about the validity of PFAS-free claims and the broader
regulatory loopholes that allow these chemicals to go unreported.
I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their
synthetic turf products is PFAS-free. However, this guarantee does not inspire
confidence for several reasons. First, FieldTurf does not provide total fluorine (TF)
testing, which is critical for detecting hidden PFAS, including polymeric PFAS and
precursors. Second, they do not specify detection limits for their PFAS tests—without
knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals,
ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this
statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free
certification.This raises an important question: What kind of PFAS-free guarantee does
TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning
board must obtain and critically evaluate TenCate’s PFAS-free claims, including their
detection thresholds, test methods, and whether they include total organic fluorine
TOF) and total oxidizable precursors (TOP) testing. Without this information, the
board has not taken the "hard look" required under SEQRA. Given that PFAS have
been found in artificial turf products marketed as "PFAS-free," it is reckless to assume
that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s
guarantee.Additionally, I want to note that these reports have been included in Zero
Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along.
It is disappointing that the town planning board is moving forward with a Negative
Declaration for the EIA despite these submissions, appearing to yield to political
pressure from Cornell University rather than prioritizing scientific integrity and the
protection of our community’s health and environment.Hereby, we have submitted this
evidence for your review, ensuring that the record reflects these critical findings, which
you are choosing to disregard as you move forward with a Negative Declaration.
Sincerely,
Larri Richmond
1139 Ellis Hollow Rd.
Ithaca, NY 14850
References:
1. Lowell Center for Sustainable Production, University of Massachusetts
Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf:
Academic, Municipal, and Other Testing Efforts. August
2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in-
Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18-386957.pdf?
rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0.
The compilation of PFAS testing from academic, municipal, and independent
studies confirms that PFAS have been detected in all components of artificial
turf, including turf blades, carpet backing, infill, shock pads, adhesives, and
even product packaging. Total fluorine (TF) testing consistently found fluorine
across various samples, with concentrations ranging from 16 to 661 µg/g (ppm),
suggesting the widespread use of polymeric PFAS, fluorinated coatings, or
PFAS-based processing aids. Extractable PFAS tests detected long- and short-
chain PFAS in multiple studies, particularly fluorotelomer alcohols (FTOHs) in
crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS
precursors in adhesives and shock pads. Municipal and nonprofit-led testing
further corroborates these findings, with PFAS measured in stormwater runoff,
installation materials, and artificial turf fields marketed as ‘PFAS-free.’ These
results highlight significant gaps in industry claims and emphasize the need for
stricter regulations and improved testing methodologies to assess the full extent
of PFAS contamination in artificial turf systems.
2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the
Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth,
NH. October 22,
2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas-statement-
fieldturf-1.pdf
A supplier for FieldTurf/Tarkett Sports claims that their artificial turf
filaments/fibers are fluorine-free and do not contain PFAS, including PFOS,
based on manufacturing consistency and compliance with REACH
regulations. However, the declaration lacks total fluorine testing, does not
specify PFAS detection limits, and does not test the full turf system, meaning
polymeric PFAS or precursors could still be present. Additionally, there is no
independent third-party verification, making the PFAS-free claim scientifically
weak and incomplete.
3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A
Zero Waste Ithaca Bibliography. Updated March 16, 2025
https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-
s_4bfbmO26R-Q/edit?usp=sharing
From:
To:
Cc:
Subject:
Sent:
Regi Teasley
Town Of Ithaca Planning; Conservation Board;
Regi Teasley
Leopold’s lesson for us
3/13/2025 11:57:41 AM
WARNING** This email comes from an outside source. Please verify the from address, any
URL links, and/or attachments. Any questions please contact the IT department
Good People,
In order to respond to the continuing degradation of our Earth: the biosphere in which we live,
we must be able to reconceptualize our relationship with Nature. Otherwise we keep making the
same mistakes that jeopardize all species, including ours.
Thank you for thinking deeply about this.
Regi Teasley
Ithaca, NY
Protect what is left, recover what is lost of the fair earth.
William Morris, “Art and the Beauty of the Earth.” 1881
Subject: Misrepresentation of Injury Data in Cornell’s Synthetic Turf Submissions
Dear Town Planning Board Members,
Gould et al.’s 2022 study regarding injury rates on artificial turf versus natural grass appears on
page 9 in the July 2024 “Additional Materials” submitted to the City and Town of Ithaca Planning
Board. The document states: “this article has been responded to previously within these
materials.”
Upon reviewing the earlier April 2024 “Additional Materials,” I found no additional mentions of
Gould. This discrepancy seems to suggest that Cornell University is misrepresenting their own
submissions.
Cornell again references this study on page 8 of their February 21 supplemental materials
submission, as seen below, presenting a misleading interpretation of its findings. Cornell asserts
that overall injury rates between synthetic and natural turf are similar, and downplays key
conclusions that highlight significant safety concerns associated with artificial turf, particularly in
relation to foot and ankle injuries.
Gould et al. (2022) conducted a systematic review of 53 studies published between 1972 and
2020. The study unequivocally found that foot and ankle injuries occur at a higher rate on
artificial turf—both old and new generations—compared to natural grass. By emphasizing that
overall injury rates" are similar while neglecting the significant differences in foot and ankle
injuries, Cornell misleads the reader. Furthermore, while knee injury rates were generally
comparable, elite-level football players were more likely to sustain knee injuries on artificial turf.
Furthermore, importantly, the study noted that all research claiming a higher injury rate
on natural grass was industry-funded, raising concerns about bias.
Cornell’s summary strategically downplays these critical findings, failing to acknowledge the
study’s strong conclusions regarding increased injury risks. Instead, it shifts focus to adherence
to “international safety standards,” which are not the subject of the study and do not negate the
evidence of elevated injury risks.
It is crucial that Cornell provides an honest and complete representation of the scientific
literature rather than selectively framing research to justify synthetic turf installation. The safety
risks highlighted in Gould et al. (2022) warrant serious reconsideration of synthetic turf use,
particularly given the well-documented biomechanical disadvantages of artificial surfaces, such
as increased rotational stiffness and frictional forces that contribute to injury.
A responsible approach would be to prioritize athlete safety by acknowledging the full scope of
scientific findings rather than distorting them to fit a predetermined agenda.
I have attached the full Gould et al. (2022) article to the bibliography. Planning Board members
are encouraged to consult the study directly and determine for themselves who is accurately
representing the truth.
Sincerely,
Jill Kellner
Reference:
Gould HP, Lostetter SJ, Samuelson ER, Guyton GP. “Lower Extremity Injury Rates on Artificial
Turf Versus Natural Grass Playing Surfaces: A Systematic Review.” The American Journal of
Sports Medicine. May 20, 2022. https://doi.org/10.1177/03635465211069562
Lower Extremity Injury Rates
on Artificial Turf Versus Natural
Grass Playing Surfaces
A Systematic Review
Heath P. Gould,MD , Stephen J. Lostetter,y Eric R. Samuelson,z MS,
and Gregory P. Guyton,MD
Investigation performed at MedStar Union Memorial Hospital, Baltimore, Maryland, USA
Background:No study has provided a comprehensive systematic review of sports injuries on artificial turf versus natural grass.
Purpose:To comprehensively examine the risk of overall injuries and multiple types of lower extremity injuries across all sports,
all levels of competition, and on both old-generation and new-generation artificial turf.
Study Design:Systematic review; Level of evidence, 3.
Methods:A systematic review of the English-language literature was performed according to PRISMA (Preferred Reporting Items
for Systematic Reviews and Meta-Analyses) guidelines. All included articles compared overall injury rates or lower extremity (hip,
knee, or foot and ankle) injury rates on artificial turf and natural grass. All sports, levels of competition, and turf types were
included. Studies were excluded if they did not include overall injury rates or lower extremity injury rates. Because of the hetero-
geneity of the included studies, no attempt was made to aggregate risk ratios to conduct a quantitative meta-analysis.
Results:A total of 53 articles published between 1972 and 2020 were identified for study inclusion. Most studies on new-gen-
eration turf (13/18 articles) found similar overall injury rates between playing surfaces. When individual anatomic injury locations
were analyzed, the greatest proportion of articles reported a higher foot and ankle injury rate on artificial turf compared with nat-
ural grass, both with old-generation (3/4 articles) and new-generation (9/19 articles) turf. Similar knee and hip injury rates were
reported between playing surfaces for soccer athletes on new-generation turf, but football players, particularly those at high levels
of competition, were more likely to sustain a knee injury on artificial turf than on natural grass.
Conclusion:The available body of literature suggests a higher rate of foot and ankle injuries on artificial turf, both old-generation
and new-generation turf, compared with natural grass. High-quality studies also suggest that the rates of knee injuries and hip
injuries are similar between playing surfaces, although elite-level football athletes may be more predisposed to knee injuries
on artificial turf compared with natural grass. Only a few articles in the literature reported a higher overall injury rate on natural
grass compared with artificial turf, and all of these studies received financial support from the artificial turf industry.
Keywords:artificial turf; natural grass; playing surfaces; injury risk; football; soccer
Since the installation of the first synthetic turf playing sur-
face in 1966 at the Astrodome in Houston, Texas, artificial
turf has emerged as a common alternative to natural grass
at all levels of competition, from youth to professional.
Compared with natural grass, artificial turf offers several
potential advantages in terms of cost, durability, mainte-
nance requirements, and multipurpose use.14 However,
concerns about athlete safety on artificial turf were raised
as early as the 1970s, with the first reports of higher injury
rates on artificial turf playing surfaces compared with nat-
ural grass.1,5 Biomechanical evidence pertaining to the
shoe-surface interface and foot-loading patterns has pro-
vided further support for concerns about artificial turf
from a player health perspective.31 Mechanical properties
such as peak torque and rotational stiffness are thought
to be substantially higher on artificial turf compared
with natural grass, potentially leading to increased fric-
tional forces between the foot and the playing surface
that could predispose athletes to a higher risk of inju-
ries.6,9,29 Moreover, higher relative loads on the central
forefoot and lesser toe areas on artificial turf have been
demonstrated to cause greater foot inversion, which could
potentially result in lateral ankle ligament injuries.11,16,33
5-in-5
M
The American Journal of Sports Medicine
2023;51(6):1615–1621
DOI: 10.1177/03635465211069562
2022 The Author(s)
1615
Team Physician’s Corner
However, the heterogeneity of study designs in the clini-
cal literature has made it difficult to draw definitive conclu-
sions with regard to the safety of artificial turf. Previous
review articles on overall injury rates,7,10,28,31,32 sport-spe-
cific injury rates,25,30 and injury rates for a specific diagnosis,
such as a concussion 21 or anterior cruciate ligament rup-
ture,4 are narrow in scope or narrative in format (nonsystem-
atic). Given the presence of multiuse playing surfaces at the
youth, high school, and collegiate levels, a more comprehen-
sive overview of the literature may provide valuable informa-
tion for sports medicine care providers and to athletic
administrators. We are not aware of any systematic review
that has examined comparative injury rates between artifi-
cial turf and natural grass including all sports, all levels of
competition, and both old- and new-generation artificial
turf types for a wide range of musculoskeletal diagnoses.
The objective of the present study was to conduct a sys-
tematic review comprehensively examining the compara-
tive risk of lower extremity injuries on artificial turf and
natural grass playing surfaces. It was not possible to
aggregate risk ratios to conduct a quantitative meta-
analysis because of the heterogeneity of the included stud-
ies with regard to sport, level of competition, artificial turf
type, injury setting (ie, practice, game), and how injury
incidence was reported. We performed a qualitative analy-
sis of the literature on the overall injury risk and the risk
of injuries to the foot and ankle, knee, and hip on artificial
turf versus natural grass across all sports, levels of compe-
tition, injury settings, and types of artificial turf.
METHODS
This systematic review was performed according to
PRISMA (Preferred Reporting Items for Systematic
Reviews and Meta-Analyses) guidelines (Figure 1).19 A
health sciences librarian developed the search strategy uti-
lizing a combination of keywords and database-specific
subject headings related to each concept including turf,
grass, and injury. A search was conducted within PubMed,
Embase (via Ovid), Web of Science Core Collection, and
SPORTDiscus (via EBSCOhost) from inception to August
12, 2020. No limit regarding the year of publication was
imposed. Non-English and nonhuman studies were
excluded from the search, and duplicates were removed
using EndNote X9 (Clarivate Analytics).
Articles were assessed for study eligibility by 2
reviewers, each of whom was blinded to the inclusion/exclu-
sion decisions made by the other reviewer. The 2 reviewers,
a senior orthopaedic surgery resident (H.P.G.) and an
academic foot and ankle orthopaedic surgeon (G.P.G.),
developed an algorithm for initial article screening, oversaw
implementation with a team of premedical and medical stu-
dents, and performed a detailed review of all included
articles. In cases of a disagreement between the 2 reviewers,
blinding was removed, and the eligibility of the article was
determined by a group consensus, with the senior author
G.P.G.) making the final decision. Studies were included
if they compared artificial turf and natural grass playing
surfaces with regard to the rate of overall injuries or any
type of lower extremity injuries, such as the hip, thigh,
knee, lower leg, ankle, or foot. Pediatric and adult studies
were included. Studies that reported only upper extremity,
chest, abdomen, spine, or concussion injury rates were
excluded. Only original research studies were included.
Studies that reported only injury rates on artificial turf or
natural grass without a direct comparison between the 2
playing surfaces were excluded. All abstracts and full-text
Figure 1.PRISMA (Preferred Reporting Items for Systematic
Reviews and Meta-Analyses) diagram showing the identifica-
tion of included studies.
Address correspondence to Gregory P. Guyton, MD, c/o Lyn Jones, MA, ELS, Department of Orthopaedic Surgery, MedStar Union Memorial Hospital,
3333 North Calvert Street, Suite 400, Baltimore, MD 21218, USA (email lyn.m.jones@medstar.net).
Department of Orthopaedic Surgery, MedStar Union Memorial Hospital, Baltimore, Maryland, USA.
yMassachusetts Institute of Technology, Cambridge, Massachusetts, USA.
zGeorgetown University School of Medicine, Washington, District of Columbia, USA.
Submitted July 21, 2021; accepted November 9, 2021.
One or more of the authors has declared the following potential conflict of interest or source of funding: G.P.G. has received royalties and payments for
services other than consulting from Wright Medical Technology, consulting fees from Paragon 28, and hospitality payments from Supreme Orthopedic Sys-
tems. AOSSM checks author disclosures against the Open Payments Database (OPD). AOSSM has not conducted an independent investigation on the
OPD and disclaims any liability or responsibility relating thereto.
1616 Gould et al The American Journal of Sports Medicine
articles were stored in Rayyan QCRI,22 which allowed blind-
ing of each independent reviewer to the inclusion/exclusion
decisions made by the other reviewer throughout the article
assessment process.
Articles that met the eligibility criteria underwent data
extraction for study design (prospective, retrospective, ran-
domized controlled trial, cohort, case-control), level of evi-
dence (1-5), cohort selection process (ad hoc, systematic),
sport (football, soccer, other), level of competition (profes-
sional, amateur), injury setting (practice, game, practice
and game), number of athletic seasons, and turf type (old
generation, new generation, not reported). Specific injury
information was also extracted from each article, including
athlete exposures, number of practices/games, number of
injuries, injury diagnoses, and injury mechanisms. Study
funding sources were also considered.
Articles that did not state the level of evidence were
independently graded for level of evidence by the same 2
blinded reviewers. Level 1 articles included high-quality
randomized controlled trials, level 2 articles included lower
quality randomized controlled trials and prospective cohort
studies, and level 3 articles included retrospective cohort
and case-control studies. Studies that did not exclude eligi-
ble athletes and used predefined enrollment criteria (eg,
entire division, entire conference, entire league) were clas-
sified as using systematic cohort selection. Studies were
classified as using ad hoc cohort selection if the study
excluded some eligible athletes and if the participants
were not enrolled according to predefined criteria (eg, ath-
letes from several teams were included, but there was no
stated rationale for inclusion). Articles were defined as
industry funded if the authors received financial support
for the research from a company that produces, sells, or
distributes artificial turf.
RESULTS
Characteristics of Included Studies
Details of the literature search strategy are summarized in
Figure 1. A total of 53 studies met inclusion criteria (see
Appendix). Article publication dates ranged from 1972 to
2020. Of the 53 studies, 33 (62.3%) were prospective, and
20 (37.7%) were retrospective. The most common study
design was cohort studies (n = 36; 67.9%), followed by case-
control studies (n = 15; 28.3%). Randomized controlled trials
accounted for only 2 (3.8%) of the included studies. All stud-
ies were rated level of evidence 3, with almost all articles
classified as either level 2 or 3 (n = 51; 96.2%) (Figure 2).
The 3 (5.7%) industry-funded studies were published by
the same author with research funding from 1 artificial
turf company (Figure 3).
Systematic cohort selection was used in 21 studies
39.6%), and ad hoc cohort selection was used in 32 studies
60.4%). A total of 24 articles (45.3%) examined football, 22
articles (41.5%) studied soccer, and 1 article (1.9%) studied
both football and soccer. Rugby (n = 4; 7.5%), ultimate Fris-
bee (n = 1; 1.9%), and field hockey (n = 1; 1.9%) comprised
the remaining 6 articles (Figure 4).
Competition level was divided equally between profes-
sional (n = 24; 45.3%) and amateur (n = 29; 54.7%) (Figure 5).
Figure 2.Diagram showing the conclusion of each article
with regard to injury rates on artificial turf and natural grass,
with articles classified by level of evidence.
Figure 3.Diagram showing the conclusion of each article
with regard to injury rates on artificial turf and natural grass,
with articles classified by industry funding status.
Figure 4.Diagram showing the conclusion of each article
with regard to injury rates on artificial turf and natural grass,
with articles classified by sport.
AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1617
The included studies were evenly split between those
that examined both games and practices (n = 27; 50.9%)
and those that examined only games (n = 25; 47.2%),
whereas the 1 remaining study (1.9%) examined only prac-
tices. The included studies tracked injury data over
a median of 3 seasons (interquartile range, 1-5). A total
of 29 articles (54.7%) reported on new-generation artificial
turf, 14 articles (26.4%) reported on old-generation artifi-
cial turf, and 10 articles (18.9%) did not report the type
of artificial turf (Figure 6).
Overall Injury Rate
Of the 32 articles that compared overall injury rates on
artificial turf and natural grass, over half (17/32; 53.1%)
reported no difference in overall injury rates between the
2 playing surfaces, 12 (37.5%) reported a higher overall
injury rate on artificial turf, and 3 (9.4%) reported a higher
overall injury rate on natural grass. Although 6 of 8
articles (75.0%) that examined overall injury rates on
old-generation turf reported a higher risk of injuries on
artificial turf, 13 of 18 articles (72.2%) that examined over-
all injury rates on new-generation turf reported no
difference between playing surfaces. A higher overall
injury rate on natural grass was reported by 3 articles
9.4%), all of which utilized ad hoc cohort selection and
were the only included studies that were industry funded.
Foot and Ankle Injury Rate
A total of 25 articles compared foot and ankle injury rates on
artificial turf and natural grass. The greatest proportion of
these studies (12/25; 48.0%) reported a higher rate of foot
and ankle injuries on artificial turf than natural grass,
whereas 10 (40.0%) found no difference in foot and ankle
injury rates between playing surfaces, and 3 (12.0%) reported
a higher foot and ankle injury rate on natural grass. Of these
3 studies, 2 (66.7%) utilized ad hoc cohort selection and were
industry funded. Although a relatively high proportion of
studies that reported on new-generation turf (9/19; 47.4%)
found a higher risk of foot and ankle injury on artificial
turf, that finding was even more frequently reported in ear-
lier articles that examined old-generation turf (3/4; 75.0%).
Knee Injury Rate
A total of 32 articles compared knee injury rates on artifi-
cial turf and natural grass. Over half of these studies (19/
32; 59.4%) found no difference in knee injury rates between
artificial turf and natural grass, whereas 8 studies (25.0%)
reported a higher knee injury rate on artificial turf, and 5
studies (15.6%) reported a higher knee injury rate on nat-
ural grass. Over two-thirds of articles (14/19; 73.7%) that
examined knee injury rates on new-generation turf
reported no difference in knee injury rates between the 2
playing surfaces, compared with a majority of studies (4/
7; 57.1%) that reported a higher knee injury rate on old-
generation turf compared with natural grass. A majority
of articles (14/16; 87.5%) reported no difference in knee
injury rates among soccer athletes, and 8 of 14 articles
57.1%) examining football athletes reported a higher
knee injury rate on artificial turf. All 3 of the industry-
funded studies reported no difference in knee injury rate
between the two playing surfaces.
Hip Injury Rate
A total of 13 articles compared hip injury rates on artificial
turf and natural grass. Of these studies, 11 (84.6%) reported
no difference in hip injury rates between playing surfaces,
while the remaining 2 studies (15.4%) reported a higher hip
injury rate on natural grass. Of the 2 studies that found
a higher risk of hip injuries on natural grass, both utilized
ad hoc cohort selection, and 1 (50.0%) received industry fund-
ing. None of the included articles reported hip injury rates in
football athletes, and none examined old-generation turf.
DISCUSSION
Although the heterogeneity of the available literature pre-
cludes a quantitative meta-analysis, this qualitative sys-
tematic review of study outcomes suggests that the rates
Figure 5.Diagram showing the conclusion of each article
with regard to injury rates on artificial turf and natural grass,
with articles classified by level of competition.
Figure 6.Diagram showing the conclusion of each article
with regard to injury rates on artificial turf and natural grass,
with articles classified by artificial turf type. Gen, generation.
1618 Gould et al The American Journal of Sports Medicine
of overall injuries, hip injuries, and knee injuries are similar
between playing surfaces. Earlier studies suggested
a greater risk of these types of injuries on old-generation
turf, but more recent data note an equivalent injury risk
on new-generation turf compared with natural grass for
most athletes. Foot and ankle injury rates are a notable
exception to this trend in that the risk of foot and ankle inju-
ries has remained higher on new-generation turf compared
with natural grass, though still less than that on old-gener-
ation turf. These conclusions were not affected by the con-
flicting findings of the 3 included studies that received
financial support from the artificial turf industry.
A majority of the included studies in this systematic
review utilized ad hoc cohort selection, which raises con-
cerns about the study design. Study cohorts that are
defined in an ad hoc manner introduce the possibility of
bias because of differences that may exist between individ-
ual athletic programs with regard to injury-reporting ten-
dencies. Although some teams may consistently and
accurately report athletes’ injuries, others may tend to
underreport injuries whether because of inadequate docu-
mentation or underlying cultural elements that discourage
athletes and medical personnel from disclosing injuries
when they occur. These issues are of particular concern
at the youth and high school levels in which many schools
are unable to employ a full-time athletic trainer or arrange
sideline physician coverage at sporting events.15,23 The
potential effect of differences in injury-reporting practices
can be diminished by studying predefined groups of ath-
letes or athletic teams that are not created solely for the
purpose of the study. For instance, including entire divi-
sions or leagues may have less potential for bias than
studying an ad hoc collection of teams that are selected
by the study investigator. Studies sponsored by the
National Football League provide an ideal model for avoid-
ing this problem by utilizing comprehensive, standardized
injury reporting and including all teams in the league.12,16
Among the 32 articles that compared overall injury
rates, a slight majority reported no difference in the injury
risk between playing surfaces. Although one-third of
articles reported a higher overall injury rate on artificial
turf, half of these studies 1,2,5,13,24,27 utilized first- and sec-
ond-generation turf types that are now considered obso-
lete. Thus, whereas a higher overall injury rate might
have existed on earlier generations of artificial turf, the
more recent literature indicates that this risk has been
ameliorated with the widespread adoption of new-genera-
tion turf since it was developed in the late 1990s.
There were 3 outlier articles that found a higher overall
injury rate on natural grass compared with new-genera-
tion turf.17-19 These studies all utilized ad hoc cohort selec-
tion and thus had a high inherent risk of bias, a concern
acknowledged by the author himself. All 3 studies were
also supported by turf industry funding. Our results with
regard to the overall injury rate coincide with the findings
of previous narrative reviews,7,31 which also concluded
that the risk of overall injuries appears to be similar
between artificial turf and natural grass.
Of the 25 included articles that examined foot and ankle
injury rates in isolation, the greatest proportion found
a higher foot and ankle injury rate on artificial turf, and
this trend persisted when studies examining new-
generation turf were analyzed separately. Only 3
articles17,19,26 reported a higher risk of foot and ankle inju-
ries on natural grass, 2 of which utilized ad hoc cohort
selection and received artificial turf industry funding.17,19
Thus, the literature appears to support the conclusion
that the risk of foot and ankle injuries is at least equivalent
between playing surfaces and may be higher on artificial
turf. These findings are consistent with previous narrative
reviews that have concluded a higher risk of foot and ankle
injuries on artificial turf.28,31,32
The literature results are heterogeneous regarding the
potential association between playing surface and knee
injury. Although half of all articles reported no difference
in knee injury rates between playing surfaces, some
articles found a higher knee injury rate on artificial turf,
and others found a higher knee injury rate on natural
grass. Analysis of the studies that utilized new-generation
artificial turf revealed a higher proportion of these articles
that found no difference in knee injury rates. Interestingly,
all 3 of the articles reporting a higher knee injury rate on
new-generation artificial turf 8,12,16 were conducted among
football players at the collegiate or professional level, sug-
gesting that there may be unique factors in the elite foot-
ball population that predispose these athletes to a higher
risk of knee injuries on artificial turf compared with natu-
ral grass. These findings correspond with the results of
a previous systematic review that reported a higher risk
of anterior cruciate ligament ruptures on artificial turf
for football players but not for soccer players.4 Taken
together, the whole body of relevant literature suggests
that the risk of knee injuries is similar on artificial turf
and natural grass for most athletes but that football play-
ers, particularly those at high levels of competition, may be
more likely to sustain a knee injury on artificial turf than
natural grass.
Relatively few articles in the literature have compared
hip injury rates on artificial turf and natural grass. Of
these 13 studies, the majority found no difference in hip
injury rates between playing surfaces, whereas only 2
articles cited a higher risk of hip injuries on natural grass.
Consistent with observations in overall injuries and foot
and ankle injuries, both of the articles that reported
a higher hip injury rate on natural grass utilized ad hoc
cohort selection, and 1 of the 2 studies 3,19 was funded by
the artificial turf industry.19 The only study not funded
by the turf industry that found a higher hip injury rate
on natural grass was a prospective cohort investigation
that examined injury rates in a small ad hoc group of the
Saudi National Team soccer players that yielded a very
low number of injuries.3 The findings of this systematic
review appear to indicate that the risk of hip injuries is
comparable between artificial turf and natural grass.
There were several limitations to this systematic
review. The wide variability in study methods, particularly
in terms of how athlete exposures were reported, made it
impossible to perform a quantitative meta-analysis using
aggregate risk ratios. Our systematic review design was
unable to account for the fact that the underlying injury
rates among different sports, levels of competition, and
injury settings may be inherently different. Similarly,
our methods did not permit the assessment of other varia-
bles that may affect injury rates such as differences in turf
AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1619
composition, athletic footwear, and field conditions. No
restrictions were made in terms of study quality, and no
formal weighting process was performed, thereby limiting
our ability to differentiate the more reliable injury data
from the less reliable data among the included articles.
For these reasons, our systematic review should be inter-
preted as a global snapshot of the literature, and our find-
ings are not intended to replace the interpretation of high-
quality individual studies that focus on specific athletic
populations with specific types of injuries.
CONCLUSION
The available body of literature suggests a higher rate of
foot and ankle injuries on artificial turf compared with nat-
ural grass on both old- and new-generation turf. High-
quality studies also suggest that the rates of knee injuries
and hip injuries are similar between playing surfaces,
although elite-level football athletes may be more predis-
posed to knee injuries on artificial turf compared with nat-
ural grass. Only a few articles in the literature reported
a higher overall injury rate on natural grass compared
with artificial turf, and all of these studies received finan-
cial support from the artificial turf industry.
ACKNOWLEDGMENT
The authors thank Lyn Camire Jones, MA, ELS, of the Depart-
ment of Orthopaedic Surgery, MedStar Union Memorial Hospi-
tal, for editorial assistance and C. Scott Dorris, MLIS, AHIP, for
assistance in performing the literature search.
ORCID iDs
Heath P. Gould https://orcid.org/0000-0002-8941-8811
Gregory P. Guyton https://orcid.org/0000-0002-1238-3673
An online CME course associated with this article is avail-
able for 1 AMA PRA Category 1 Credit TM at https://
www.sportsmed.org/aossmimis/Members/Education/AJSM
Current_Concepts_Store.aspx. In accordance with the
standards of the Accreditation Council for Continuing Med-
ical Education (ACCME), it is the policy of The American
Orthopaedic Society for Sports Medicine that authors, edi-
tors, and planners disclose to the learners all financial rela-
tionships during the past 12 months with any commercial
interest (A ‘commercial interest’ is any entity producing,
marketing, re-selling, or distributing health care goods or
services consumed by, or used on, patients). Any and all
disclosures are provided in the online journal CME area
which is provided to all participants before they actually
take the CME activity. In accordance with AOSSM policy,
authors, editors, and planners’ participation in this educa-
tional activity will be predicated upon timely submission
and review of AOSSM disclosure. Noncompliance will
result in an author/editor orplannertobestrickenfrom
participating in this CME activity.
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in Iceland. Scand J Med Sci Sports. 1996;6(1):40-45.
3. Almutawa M, Scott M, George KP, Drust B. The incidence and nature
of injuries sustained on grass and 3rd generation artificial turf: a pilot
study in elite Saudi national team footballers.Phys Ther Sport.
2014;15(1):47-52.
4. Balazs GC, Pavey GJ, Brelin AM, Pickett A, Keblish DJ, Rue JP. Risk
of anterior cruciate ligament injury in athletes on synthetic playing sur-
faces: a systematic review.Am J Sports Med. 2015;43(7):1798-1804.
5. Bramwell ST, Requa RK, Garrick JG. High school football injuries: a pilot
comparison of playing surfaces.Med Sci Sports. 1972;4(3):166-169.
6. Dowling AV, Corazza S, Chaudhari AM, Andriacchi TP. Shoe-surface
friction influences movement strategies during a sidestep cutting
task: implications for anterior cruciate ligament injury risk.Am J
Sports Med. 2010;38(3):478-485.
7. Dragoo JL, Braun HJ. The effect of playing surface on injury
rate: a review of the current literature.Sports Med. 2010;40(11):
981-990.
8. Dragoo JL, Braun HJ, Harris AH. The effect of playing surface on the
incidence of ACL injuries in National Collegiate Athletic Association
American Football.Knee. 2013;20(3):191-195.
9. Drakos MC, Hillstrom H, Voos JE, et al. The effect of the shoe-sur-
face interface in the development of anterior cruciate ligament strain.
J Biomech Eng. 2010;132(1):011003.
10. Drakos MC, Taylor SA, Fabricant PD, Haleem AM. Synthetic playing
surfaces and athlete health.J Am Acad Orthop Surg. 2013;21(5):293-
302.
11. Ford KR, Manson NA, Evans BJ, et al. Comparison of in-shoe foot
loading patterns on natural grass and synthetic turf.J Sci Med Sport.
2006;9(6):433-440.
12. Hershman EB, Anderson R, Bergfeld JA, et al. An analysis of specific
lower extremity injury rates on grass and FieldTurf playing surfaces in
National Football League games: 2000-2009 seasons.Am J Sports
Med. 2012;40(10):2200-2205.
13. Jamison S, Lee C. The incidence of female hockey injuries on grass
and synthetic playing surfaces.Aust J Sci Med Sport.1989;21:15-17.
14. Jastifer JR, McNitt AS, Mack CD, et al. Synthetic turf: history, design,
maintenance, and athlete safety.Sports Health. 2019;11(1):84-90.
15. Jones NS, Sethi N, Wieschhaus K, et al. Medical supervision of Illi-
nois public and private high school athletics.Phys Sportsmed. Pub-
lished online December 31, 2020. doi: 10.1080/00913847.2020
1868954
16. Mack CD, Hershman EB, Anderson RB, et al. Higher rates of lower
extremity injury on synthetic turf compared with natural turf among
National Football League athletes: epidemiologic confirmation of
a biomechanical hypothesis.Am J Sports Med. 2019;47(1):189-196.
17. Meyers MC. Incidence, mechanisms, and severity of game-related
college football injuries on FieldTurf versus natural grass: a 3-year
prospective study.Am J Sports Med. 2010;38(4):687-697.
18. Meyers MC. Incidence, mechanisms, and severity of match-related
collegiate women’s soccer injuries on FieldTurf and natural grass sur-
faces: a 5-year prospective study.Am J Sports Med. 2013;41(10):
2409-2420.
19. Meyers MC. Incidence, mechanisms, and severity of match-related
collegiate men’s soccer injuries on FieldTurf and natural grass surfaces:
a 6-year prospective study.Am J Sports Med. 2017;45(3):708-718.
20. Moher D, Liberati A, Tetzlaff J, Altman DG; the PRISMA Group. Pre-
ferred Reporting Items for Systematic Reviews and Meta-Analyses:
the PRISMA statement.J Clin Epidemiol. 2009;62(10):1006-1012.
21. O’Leary F, Acampora N, Hand F, O’Donovan J. Association of artifi-
cial turf and concussion in competitive contact sports: a systematic
review and meta-analysis.BMJ Open Sport Exerc Med. 2020;6(1):
e000695.
1620 Gould et al The American Journal of Sports Medicine
22. Ouzzani M, Hammady H, Fedorowicz Z, Elmagarmid A. Rayyan:
a web and mobile app for systematic reviews.Syst Rev. 2016;5(1):210.
23. Post EG, Roos KG, Rivas S, Kasamatsu TM, Bennett J. Access to
athletic trainer services in California secondary schools.J Athl Train.
2019;54(12):1229-1236.
24. Powell JW. Incidence of injury associated with playing surfaces in
the National Football League 1980-1985.Athl Train. 1987;22(3):
202-206.
25. Rennie DJ, Vanrenterghem J, Littlewood M, Drust B. Can the natural
turf pitch be viewed as a risk factor for injury within association foot-
ball?J Sci Med Sport. 2016;19(7):547-552.
26. Soligard T, Bahr R, Andersen TE. Injury risk on artificial turf and grass
in youth tournament football.Scand J Med Sci Sports. 2012;22(3):
356-361.
27. Stevenson MJ, Anderson BD. The effects of playing surfaces on inju-
ries in college intramural touch football. NIRSA 1981;Recreat Sport
J(5):59-64.
28. Taylor SA, Fabricant PD, Khair MM, Haleem AM, Drakos MC. A review
of synthetic playing surfaces, the shoe-surface interface, and lower
extremity injuries in athletes.Phys Sportsmed. 2012;40(4):66-72.
29. Villwock MR, Meyer EG, Powell JW, Fouty AJ, Haut RC. Football
playing surface and shoe design affect rotational traction.Am J
Sports Med. 2009;37(3):518-525.
30. Williams JH, Akogyrem E, Williams JR. A meta-analysis of soccer
injuries on artificial turf and natural grass.J Sports Med (Hindawi
Publ Corp). 2013;2013:380523.
31. Williams S, Hume PA, Kara S. A review of football injuries on third and
fourth generation artificial turfs compared with natural turf.Sports
Med. 2011;41(11):903-923.
32. Winson DMG, Miller DLH, Winson IG. Foot injuries, playing surface
and shoe design: should we be thinking more about injury preven-
tion.Foot Ankle Surg. 2020;26(6):597-600.
33. Wright JM, Webner D. Playing field issues in sports medicine.Curr
Sports Med Rep. 2010;9(3):129-133.
For reprints and permission queries, please visit SAGE’s Web site at http://www.sagepub.com/journals-permissions
AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1621
1
From:Louise Mygatt <louisemygatt@gmail.com>
Sent:Monday, March 17, 2025 12:30 PM
To:Town Of Ithaca Planning
Cc:pbstaff@cityofithaca.org
Subject:artificial turf
Attachments:met-pfas-statement-fieldturf-1 (copy).pdf; PFAS detected in all components of Artificial
Turf - Academic Municipal & Other Tests Aug 2024_tcm18-386957-1.pdf
WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or
attachments. Any questions please contact the IT department
Dear Town Planning Board Members,
The attached August 2024 report from the University of Massachusetts Lowell confirms that
PFAS have been detected in all components of artificial turf, including blades, backing, infill,
shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its
field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is
not limited to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However,
this study, conducted by a respected research center with full citations and expert analysis, is highly
relevant to the town planning board’s review. Declaring a negative declaration without considering
this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control
the narrative by discounting high-quality investigative journalism and research from credible
organizations—especially in a rapidly evolving field where new findings emerge constantly.
Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but
testing in this report reveals PFAS were still found in those materials. This raises serious concerns
about the validity of PFAS-free claims and the broader regulatory loopholes that allow these
chemicals to go unreported.
I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products
is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First,
FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS,
including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS
tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring
precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly,
without third-party, independent verification, this statement is just a self-reported manufacturer claim
rather than a rigorous PFAS-free certification.
This raises an important question: What kind of PFAS-free guarantee does TenCate—the
manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and
critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and
whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing.
2
Without this information, the board has not taken the "hard look" required under SEQRA. Given
that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to
assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee.
Additionally, I want to note that these reports have been included in Zero Waste Ithaca's
bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the
town planning board is moving forward with a Negative Declaration for the EIA despite these
submissions, appearing to yield to political pressure from Cornell University rather than prioritizing
scientific integrity and the protection of our community’s health and environment.Hereby, we have
submitted this evidence for your review, ensuring that the record reflects these critical findings, which
you are choosing to disregard as you move forward with a Negative Declaration.
Sincerely,
Dr. Louise Mygatt
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PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1
Per-and Poly-fluoroalkyl Substances
PFAS)in Artificial Turf:Academic,
municipal,and other testing efforts
August 2024
A number of organizations have conducted PFAS testing in artificial turf materials. These include academic
studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or
vendors, sometimes with the assistance of consulting firms. This document provides a compilation of
results that have been reported from many of these testing efforts.
This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in
artificial turf, and for a discussion of key considerations related to test methods. For another recent
summary of test results, see the New Jersey Department of Environmental Protection’s Technical
Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s
report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3
Test results are summarized below for academic studies; regional and municipal studies; nonprofits,
community organizations, and journalists; and manufacturers. Testing has been carried out using a variety
of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or
precision of the methods or results.
Academic studies
Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and
expanded the information available on the presence of PFAS in these materials. Results from these studies
are summarized in Table 1.
Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and
targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm,
Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene
rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork,
bark, and coconut).
TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic
material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted
analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently.
The authors explain that “collectively, these results point toward polymeric organofluorine (e.g.,
fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2
Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be
landfilled or incinerated.
Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method
to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made
with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more
harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography-
mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb
rubber infill.
Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf
blades to determine the presence of PFAS.6
For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to
raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic
product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the
manufacturing process.
Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below
detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that
much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of
fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing
literature.
Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem
mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of
PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of
eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The
median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS
concentrations was 41.7 ng/g (ppb).
Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial
turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial
turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong
degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing
aids." This information further supports the possibility that fluorinated polymers were added to the resin.
A TOP assay was performed on four samples including artificial turf and product packaging. Because this
testing included both artificial turf and other plastic products, this information is relevant primarily for
refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did
not have significant changes in concentration after oxidation. This was likely because those samples did not
contain substantial quantities of the precursor PFAS that break down into the degradation products that
were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and
showed a higher concentration of degradation products after oxidation. This suggested that the sample
contained higher quantities of the precursors that were measured in the TOP assay.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3
A conclusion of this study was that “these results suggest that much of the total fluorine signals measured
in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what
might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that
targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various
plastic products.” In other words, this study further supports the importance of carefully choosing test
methods that can accurately characterize PFAS content in artificial turf materials.
Table 1. Summary of PFAS testing from academic studies.
Source Summary
Lauria et al.
2022)4
Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of
artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing,
carpet blades, and infill.
TOTAL FLUORINE
TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 g of F/g in
backing, filling, and blades, respectively).”
TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic
material infills.
EXTRACTABLE ORGANIC FLUORINE
Backing: range from <LOD - 145 ng of F/g (ppb)
Infill: range from <LOD - 179 ng of F/g (ppb)
Blades: range from <LOD - 192 ng of F/g (ppb)
TARGETED ANALYSIS
Results were reported as the sum of fluorine in a sample.
Backing: <LOD - 0.63 ng of F/g (ppb)
Infill: <LOD - 0.15 ng of F/g (ppb)
Blades: “absent”
Zuccaro et al.
2023)5
A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH)
in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and
analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM).
FLUOROTELOMER ALCOHOLS PILOT TEST:
8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at
concentrations of 1.0 and 0.71 ng/L [ppm], respectively. This translates to 300ng 8:2 FTOH/g
artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH
were not found to be present in detectable levels.”
Whitehead
2023)
dissertation)6
Analyzed PFAS in 27 samples of artificial turf blades using several methods.
TOTAL FLUORINE
Measured using particle-induced gamma ray emission (PIGE) spectroscopy.
TF ranged from <LOD to 2.94 µg F/cm2.
TARGETED ANALYSIS
Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC-
MS/MS)
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4
PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples
was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb).
ORGANIC FLUORINE
Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results
were “indicative of the presence of organic fluorine in these samples, with a strong degree of
similarity between spectra collected from samples to that of raw fluorinated polymer
processing aids."
TOP ASSAY (four samples only)
T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t
have significant changes in their sum of PFAS concentrations. The sample which had the
highest sum of PFAS concentrations before TOP assay showed a more significant increase in
measured concentrations.”
Results suggest that “the concentrations of fluorine measured through PIGE are likely
indicative of PFAS which does not undergo transformation” into the compounds measured in
the TOP assay.
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
Regional and Municipal Studies
The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and
two adhesives used during the installation of an artificial turf field.7 The analyses included targeted
analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic
precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both
organic and inorganic analytes present in liquids, soils, and wastes."8
PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in
the carpet, and lower quantities in other materials. Additional results are summarized in Table 2.
The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed
as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new
artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock
pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham
Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total
fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer
processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial
grass.”9
The City of Portsmouth later initiated further testing with help from a consulting group. This effort included
a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis.
The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed
presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill,
the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are
summarized in Table 2.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5
Table 2. Summary of PFAS testing led by regional institutions and municipalities.
Source Summary
Martha’s
Vineyard, MA
2020).7
Laboratory results
interpreted by
consultants at
Tetra Tech
Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives
used during field construction.
TARGETED ANALYSIS
Total PFAS by isotope dilution method”
Detected certain PFAS at concentrations above the method detection limit (MDL) but
below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb);
Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb).
Synthetic Precipitation Leaching Procedure
Select PFAS compounds were detected in the SPLP analysis that were not detected in the
total PFAS analysis.”
The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L),
shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the
adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total
PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are
equivalent to ppt.)
The detection of PFAS compounds in the samples of the synthetic turf components via
SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain
PFAS compounds that were not extractable via the analytical method utilized for total PFAS
analysis (isotope dilution method), but were extractable by the more rigorous SPLP
extraction process.”
TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY
PFAS were not detected during the pre-oxidation measurements.
The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all
sample materials at concentrations above the method detection limit but below the
reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g.
Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill]
at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)”
Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at
a concentration of 6.08 ng/g.” This concentration was above the method detection limit
but below the reporting limit, yielding an estimated value.
TOTAL ORGANIC FLUORINE
Total organic fluorine was detected in the [carpet] at a calculated concentration of 70
parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second
adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting
that the total fluorine detected in these samples likely represents primarily organic
fluorine. However, because the RL in some cases is close to the detected concentration of
total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine
was not detected in the sample of the [wood infill] above the RL of 10 ppm.”
Additional note from consultant report
The consultant noted that there were difficulties in the laboratory’s approach. “The detection
limits achieved by the laboratory were elevated because of the limited sample weight utilized
during extraction and the dilutions required by the low density sample matrix.”
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6
Portsmouth, NH
2021) initial
community
testing9
The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center,
initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad.
An independent laboratory measured total fluorine in these materials.
TOTAL FLUORINE
Carpet: TF: 83- 119 ppm
Backing: TF: 16 ppm
Shock pad: TF: 61 ppm
Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total
fluorine measurements are typical for plastics that have been manufactured with PFAS-
based polymer processing aids – which will leave residues of these PFAS at the part-per-
million level on the artificial grass.” 9
Portsmouth, NH
2022) testing
initiated by City of
Portsmouth.
Laboratory results
interpreted by
consultants at
TRC10
Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock
pad. Results summarized here show presence of substances only. See full report for
concentrations.
TARGETED TESTING AND TOP ASSAY
PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70
individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope
dilution liquid chromatography/dual mass spectrometry” in samples of material. This method
is considered a targeted test method. Samples were also oxidized and measured for PFAS
precursors.
Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples.
Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was
also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].”
Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was
also detected in a blank sample). Six PFAS were detected in samples after oxidation.
Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA
was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a
concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation.
NON-TARGETED ANALYSIS
Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were
performed on each sample to determine if “other” PFAS were present that were not included
in the analysis of the 70 individual PFAS.”
Results were “qualitative estimations of presumptive positives.” Several additional
chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl)
carbonate, was tentatively identified in the carpet sample. The other chemicals were
reported as “unknown.”
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking
water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7
Nonprofits, Community Organizations, and Journalists
A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial
turf. Below are some examples.
Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet
and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11
The organizations tested backing of both new turf and older, discarded turf. They also tested a number of
samples of artificial grass blades (carpet fibers).
They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA
has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In
many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS.
They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is
a long-chain PFAS that is no longer manufactured in the US due to concerns about health and
environmental effects.
They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of
fluorine that suggest the presence of PFAS.11
Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted
samples of new and older turf to commercial and research laboratories for various types of PFAS analyses.
Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected
from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS-
free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after
the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS
measured after installation were higher than the levels measured before installation. Three other PFAS
were also detected in the post-installation stormwater samples (see Table 3).
Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the
Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre
Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12
ppt) and PFOS (5.5 ppt).
PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8
Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists.
Source Summary
NONPROFIT AND COMMUNITY ORGANIZATIONS
Testing reported in
The Intercept
2019).11 Results
summarized by New
Jersey Department of
Environmental
Protection.2
Targeted and total fluorine testing conducted on new turf carpet samples; targeted
testing conducted on used sample.
TARGETED ANALYSIS
New turf carpet sample: 6:2 FTSA: 300 ppt
Used turf carpet sample: PFOS: 190 ppt
TOTAL FLUORINE ANALYSIS
New turf carpet blades: 44-255 ppm
Woodbridge, CT
2021)12
Samples of stormwater runoff were collected before and after the installation of an
artificial turf field from a swale located near the artificial turf field installation site.
Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS.
TARGETED ANALYSIS of runoff
Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt)
After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L
ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt)
Preliminary dermal
exposure tests by
Public Employees for
Environmental
Responsibility
PEER)13
Used skin wipes to measure PFAS on four individuals before and after play. Results
showed differences in pre- and post-play PFAS levels for artificial turf and grass.
Center for
Environmental
Health (CEH)14,15
CEH tested samples of artificial grass used for residential applications. PFOS was
detected during testing. Based on the levels detected, CEH sent California Proposition
65 notices of violation to relevant parties.
JOURNALIST
Philadelphia Inquirer
2023)16
The Philadelphia Inquirer purchased samples of artificial turf carpet used by
Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and
University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS.
TARGETED ANALYSIS
Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt).
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods
or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or
ppt in parentheses for ease of interpretation. <LOD = below level of detection.
Manufacturers
Determining which chemicals are present in a product can be challenging because chemical contents are
frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9
manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of
two manufacturers that have provided test data.
As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and
PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in
determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the
two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was
detected above this threshold.
Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The
manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts
consulted by the journalists suggested that the laboratory test results had limited value, in part because of
high detection limits.18
In some cases, targeted tests have been used to inform PFAS-free statements. For example, one
manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at
100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17
In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term
PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100
ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile
products.21)
Table 4. Examples of PFAS testing led by manufacturers.
Source Summary
Artificial turf
manufacturer example
1 (2023)17
The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of
PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting
solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The
lowest calibrated detection is at 100 parts per trillion.”
TARGETED ANALYSIS OF PFOA AND PFOS
PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect
concentrations below 100 ppt.
Artificial turf
manufacturer example
2 (2022)22
Results summarized by
The Philadelphia Inquirer
2024)18
The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI
Laboratories Inc. for targeted PFAS testing.
TARGETED ANALYSIS
The laboratory’s summary of results stated that “all extractable PFAS compounds
were non-detect at a level of 2-4 ug/kg (ppb).”22
Experts consulted by The Philadelphia Inquirer expressed concerns about the testing
methods and the high detection limits used. They noted that lower detection limits
and a total organic fluorine test would have yielded results that are more
informative.18
Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or
results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in
parentheses for ease of interpretation. <LOD = below level of detection.
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10
Acknowledgments
This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable
Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger-
Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather
Whitehead, PhD.
This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same
authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl
Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra
Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection,
State of New Jersey. Research for this report was supported by The Heinz Endowments.
The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative
strategies for communities and workplaces to adopt safer and sustainable practices and products to protect
human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students
at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions,
and government agencies to build healthy work environments, thriving communities, and viable businesses
that support a more sustainable world.
References
1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances
PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18-
385224.pdf (July 2024).
2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in
artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023).
3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory
Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023).
4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from
Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672.
5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols
FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber
infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280.
6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant
to human health and the environment (dissertation),
https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A
nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023).
7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report,
https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL
February 2021).
8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure,
https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024).
9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021,
https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new-
synthetic-turf-field/ (2021).
PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11
10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf,
https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf
2022).
11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019,
https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October
2019).
12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021.,
https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021).
13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin,
https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024).
14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act:
Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document.,
https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024).
15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024.,
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024).
16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed.
Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas-
forever-chemicals-cancer-20230307.html (2023).
17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp-
content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024).
18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The
Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-
turf-field-murphy-recreation-20240223.html (23 February 2024).
19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and-
artificial-grass/ (2023, accessed 5 June 2024).
20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/.
21. State of California. CA Health & Safety Code § 108945,
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha
pter=12.5.&article= (2022).
22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022,
https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022).
From:
To:
Subject:
Sent:
Tulesi Suresh
Town Of Ithaca Planning
Opposition to Artificial Turf
3/18/2025 8:05:03 AM
WARNING** This email comes from an outside source. Please verify the from address, any URL links,
and/or attachments. Any questions please contact the IT department
Good morning,
Id like to submit a written comment opposing the installment of artificial turf on Cornell’s campus and off
campus due to their negative impacts on environmental and human health. This decision goes against
sustainability efforts and is not a wise decision.
Best,
Tulesi Suresh
1
March 11, 2025
Dear Members of the Town of Ithaca Planning Board,
I am writing to you with an update to my previous letter from February 28, 2025 to present you with
the most recent data and analysis to ensure that the public record is current. In response to
concerns raised about artiflcial turf, a dedicated group offleld hockey parents and alumnae
undertook an exhaustive review of the 151-page bibliography provided by Zero Waste Ithaca on their
website (dated February 10, 2025). Our approach was meticulous and data-driven:
We started with 1,539 hyperlinks embedded in the document, of which 877 were
duplicates, leaving us with 662 unique sources.
We then excluded non-scientiflc materials, such as personal opinions, news articles,
community letters, conference manuscripts, lawsuits, manufacturers information,
statements from advocacy groups, and YouTube videos. These sources, while valuable in
the context of public discourse, do not meet the rigorous standards of scientiflc research.
We also excluded 11 sources or hyperlinks that pointed to the same peer-reviewed study
We further reflned our list by focusing only on peer-reviewed studies published in scientiflc
journals, as these represent the highest standard of credible research. This process left us
with 162 peer-reviewed studies, plus one EPA study that we included.
Exhibit 1: Analysis of sources referenced in the bibliography of Zero Waste Ithaca (as of February
10, 2025)
Upon closer examination of the 163 peer-reviewed studies:
o 106 of these studies did not address artiflcial turf at all.
o 30 studies focused on turf containing inflll materials, which is not relevant to this
project because the proposed fleld will not use crumb rubber inflll.
o An additional 27 studies were not relevant because their subject was turf that was
not only not the speciflc type of turf that is proposed, but not even in the general
category of fleld hockey turf. These included studies whose subject was football
1,539
662
163
877)
488)
11)
Total Hyperlinks Duplicate Hyperlinks Unique Hyperlinks Non-peer-reviewed
Sources
Duplicate studies Peer-reviewed
Studies
2
turf, general use recreational turf, park coverings, playground turf, as well as
laminate fiooring.
Exhibit 2: Review of 163 peer-reviewed studies referenced in the bibliography of Zero Waste Ithaca
as of February 10, 2025)
The updated number of peer-reviewed studies compared to my previous letter and analysis still
leaves us with zero studies that demonstrate a relationship between the artificial turf in the
proposal for the field hockey turf, and any harm caused to the environment or people.
Again, thank you very much for your willingness to serve on the Planning Board and for all your hard
work on this decision. I truly appreciate your service.
Respectfully,
Beatrice Lechner MD
Associate Professor of Pediatrics (retired)
Alpert Medical School of Brown University
163
106)
30)
27)
Peer-reviewed
Studies
Not Artifical Turf Turf with Infill Not FH Turf Relevant Scientific
Studies
0
From:
To:
Subject:
Sent:
bethany ojalehto mays
Town Of Ithaca Planning
Planning Board submission: Correction to article on field hockey turf by
Z. Faraj
3/16/2025 1:24:00 PM
Dear Planning Board staff;
Appended below, I submit a letter of correction sent to The Cornell Daily Sun for inclusion in the
public record for the Game Farm Road Project. This letter clarifies how Cornell's bad-faith SEQR
segmentation has created a situation that exerts unusual emotional, intense public pressure upon
the Planning Board to rush a project through without adequate environmental scrutiny of its
cumulative impacts. This should also underscore the importance of a GEIS for members of the
Board, who have noted that Cornell's applications seem to change over time, and that their
promises to minimize the use of artificial turf on the Game Farm Road site should be made
binding through a GEIS.
This should be included in the record to clarify our position, and to clarify to the public why the
women's field hockey team faces a deadline crunch. In her March 4 testimony before your Board,
Cornell's applicant, Kimberly Michaels, incorrectly characterized the situation as one where "these
young women...are caught in a bunch of politics." (~3:06:10). It would be more correct to state
that these young women are caught in a timeline conflict created by Cornell's bad-faith SEQR
segmentation request.
Unfortunately, some members of your Board appear to misunderstand the situation themselves.
One Board member took the surprising position that this field hockey project is being
scapegoated." We trust that the below clarification will ensure that Board members understand
their role in upholding the integrity of the SEQR process, and that they will also ensure that
Cornell does not violate the terms of SEQR segmentation with impunity.
When your Board originally discussed Cornell's SEQR segmentation request in May 2024, Board
members stated that SEQR segmentation would only be permissible if "future phases are
functionally independent of current phases" (Bill Arms). That proved to be false. Your Board
members also stated that they would support segmentation only if it did not interfere with the
Board's ability to "give the project or the projects as much care and attention as it needs" (Cindy
Kaufman). That will also prove to be false if the Board rushes this project through an expedited
timeline under the emotional pressure of inconveniencing Cornell's field hockey season.
We support athletics, including women's field hockey. We support healthy playing fields, a livable
environment, and a Town Planning Board that upholds the integrity of SEQR law, even under
political pressure.
Thank you for considering this, and thank you for your continued attention to the integrity of
SEQR law.
take care,
bethany ojalehto mays, PhD
Forwarded message ---------
From: bethany ojalehto mays <bethany.o.mays@gmail.com>
Date: Sun, Mar 16, 2025 at 9:18 AM
Subject: Correction to article on field hockey turf by Z. Faraj
To: <managing-editor@cornellsun.com>, <zdf8@cornell.edu>
Hello Julia and Zeinab,
I'm writing to request a time-sensitive correction to the article written by Zeinab Faraj about the
women field hockey's playing field, titled "‘A Monumental Blunder’: Million-Dollar Donor Baffled
After Cornell Destroys Namesake Field Hockey Turf With No Immediate Replacement."
In their Feb 26, 2025 article, Faraj writes that "Cornell had planned to relocate the field hockey
team to a new location at Game Farm Road. However, the move has been set back. The delay in
construction follows a series of complaints about environmental concerns from Ithaca residents
over the proposed field’s use of synthetic turf."
This is incorrect. The move has not been "set back." Instead, it is proceeding exactly as it should
under the State Environmental Quality Review (SEQR) Act. Any project presented to the Planning
Board must undergo an environmental assessment to determine whether or not there is the
potential for at least one adverse environmental impact. If the Board finds that there is the
potential for at least one adverse environmental impact, then a full environmental impact
statement (EIS) is required. That EIS process may take months. It is the responsibility of all
applicants, including Cornell, to plan for that likelihood when creating their project timeline.
In the current case of the field hockey turf at Game Farm Road, the applicant (Cornell) was well
informed that this particular project could rise to the level of an environmental impact statement
EIS). When Cornell's applicant, Kimberly Michaels, requested that the Town and City Planning
Boards segment this project from Meinig Fieldhouse for purposes of environmental review last
May, she was told by the Town Planning Board members that the Game Farm Road site "needs a
very serious review...[and] is an interesting site from the SEQR point of view" (Bill Arms, at
41:10). Ms. Michaels also knew that two Town Planning Board members voted in favor of a
positive declaration of environmental significance for the Meinig Fieldhouse project - a clear
signal that they may do the same for the upcoming Game Farm Road Project.
Therefore the applicant, Cornell, had every reason to expect that the Town Planning Board could
find that the Game Farm Road project poses potential adverse environmental impacts requiring
an EIS. Cornell should have planned their project timeline accordingly. Yes, an EIS may add
months to a project's timeline: but it is by no means a "set back." It is an essential component of
the State Environmental Quality Review Act put in place to protect our shared environment. It is
the applicant's responsibility to plan multiple phases of a single project in a transparent way that
allows the Planning Board to do their job properly: it is not the Planning Board's fault if Cornell
failed to plan their projects transparently and responsibly. The fact is that Cornell (along with
every other applicant who comes before the Board) should plan their projects with enough
padding to allow time for an EIS, should that be required by the Board.
Instead of doing so, Cornell chose to break up or "segment" what was clearly one athletics
master plan project with one timeline into two smaller projects: the Meinig Fieldhouse Project
and the Game Farm Road project. To do so, Cornell petitioned the Town and City Planning Boards
to split their athletic master plan project into two smaller projects for purposes of environmental
review, known as a "SEQR segmentation" request. Of course, these are not two separate
projects, as your headline makes clear. That's exactly why Marsha Dodson is so angry. In order to
make their segmentation case, then, Cornell had to misrepresent the facts. In May 2024,
Cornell's applicant Ms. Michaels testified before the Town Planning Board that the Game Farm
Road and Meinig Fieldhouse projects were "functionally independent," on "different timelines,"
only "mildly related," that "there is no relationship there" [between the two projects], and that
the approval of the Meinig Fieldhouse "would not commit" the Town Planning Board to approve
the Game Farm Road Project. These claims misrepresented the situation, as your article's
headline and Marsha Dodson make clear. Athletics Director Nicki Moore herself conceded that
these two projects are "interconnected" in her announcement to the Athletics Community cited in
your article. This directly contradicts Cornell's SEQR-segmentation narrative that the two projects
are "functionally independent" and "on different timelines." For details and documentation,
please refer to my public comments on this topic submitted in December, January and February.
Now, Cornell is pressuring the Town Planning Board to rush approval of their Game Farm Road
project without a proper environmental review -- because Cornell misrepresented the fact that
these two projects are not functionally independent and are not on different timelines. Does
Cornell misrepresent the facts with impunity? This is not a mere technical issue: it gives the
appearance of a strategic approach to misrepresenting the facts in order to evade proper
environmental review.
Why would Cornell want to segment these two projects for purposes of environmental review?
Historically, this has often occurred in cases where the applicant wishes to evade scrutiny of the
cumulative environmental impacts of a large action. One large project is more likely to trigger an
EIS than two smaller projects. If the applicant can succeed in convincing the Planning Board(s)
that their large project is actually two smaller ones for purposes of environmental review, then
they can ensure that the cumulative impacts of the overall action are ignored. This is illegal.
According to NY State Law: “If an action consists of multiple phases, sets of activities, or if
separate agencies are involved, SEQR requires agencies jointly consider these cumulative impacts
during their review. Segmentation of an action into smaller components for an individual review
contradicts the intent of the law and may result in legal action.”
To be perfectly clear: it is not the Town Planning Board's fault, or environmentalists' fault, if
Cornell's proposed plan poses adverse environmental impacts that require an EIS that adds
several months to the project's timeline. If Cornell chooses to design projects that pose potential
adverse health and environmental consequences, then it is their responsibility and obligation to
ensure that those projects are prepared to undergo full and appropriate environmental review. It
is Cornell's responsibility to plan their athletic master plan project timeline in such a way as to
allow for environmental law to be properly applied. For Faraj's article to characterize this as
a "delay" caused by environmentalists and the Board is inaccurate.
Unfortunately, your article replicates the false narrative that Cornell is trying to advance in order
to inappropriately pressure the Town Planning Board to rush their inappropriately "segmented"
project through approvals without a full environmental review. Cornell wishes to expedite this
project so that they won't be inconvenienced by bussing student-athletes to Syracuse to play on
the nearest regulation women's field hockey turf for part of a season. There was a clear legal
path for Cornell to avoid this problem: they could have faithfully represented the "interconnected"
nature of these two projects as one unified master plan, and sought environmental review for the
entire project as a whole (including Meinig Fieldhouse and Game Farm Road). By taking this path,
Cornell would have ensured that the women's existing field hockey turf was not destroyed
without a replacement. Cornell chose not to do that, and instead chose to misrepresent the facts
by seeking a bad-faith SEQR segmentation.
I request that you correct this error and present the story in an accurate, balanced manner that
correctly represents the letter and intent of the State Environmental Quality Review Act.
This Tuesday's Town Planning Board meeting on 3/19 will be a decisive moment in this process
that warrants your more informed and balanced coverage.
Thank you.
Sincerely,
bethany ojalehto mays, PhD
bethany ojalehto mays
Cornell Alum & Former Assistant Professor
Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins)
Cornell on Fire | Mobilize Cornell to confront the climate emergency
Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayogo hó n’ People
the Cayuga Nation). Land acknowledgements are only the first step toward reparations,
restorative justice, and recognition. Understand more.
Do what is needed rather than what you want to do." -
Vanessa Machado de Oliveira in Hospicing Modernity
bethany ojalehto mays
Cornell Alum & Former Assistant Professor
Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins)
Cornell on Fire | Mobilize Cornell to confront the climate emergency
Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayogo hó n’ People
the Cayuga Nation). Land acknowledgements are only the first step toward reparations,
restorative justice, and recognition. Understand more.
Do what is needed rather than what you want to do." -
Vanessa Machado de Oliveira in Hospicing Modernity
From:
To:
Cc:
Subject:
Sent:
bethany ojalehto mays
Town Of Ithaca Planning
Chris Balestra
Public comment submission
3/17/2025 6:54:26 PM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town Planning Board Staff and Members,
I submit a public comment for consideration in advance of the Board's environmental determination
on the Game Farm Road Project tomorrow. The requirement for clear evidence and documentation
led to a long document, but I have summarized the main points and concerns in the 2-page letter of
introduction.
Thank you kindly for your careful consideration, and I look forward to seeing you tomorrow.
take care,
bethany
bethany ojalehto mays
Cornell Alum & Former Assistant Professor
Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins)
Cornell on Fire | Mobilize Cornell to confront the climate emergency
Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayogo hó n’ People
the Cayuga Nation). Land acknowledgements are only the first step toward reparations, restorative
justice, and recognition. Understand more.
Do what is needed rather than what you want to do." -
Vanessa Machado de Oliveira in Hospicing Modernity
From:
To:
Cc:
Subject:
Sent:
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Regi Teasley
Town Of Ithaca Planning
Regi Teasley
Science, plastic turf and Cornell University
3/17/2025 12:49:58 PM
Members of the Town of Ithaca Planning Board,
I want to alert you to a dynamic in the conversation about the artificial turf fields
Cornell is proposing.
You are regarding Cornell as a research university and center of higher learning.
This is perfectly logical given its history. Unfortunately, they are becoming something
different and, I believe, are using corporate strategies to muddy the waters and mislead
us. If you doubt this, simply look closely at Cornell’s board members, their expertise,
and their corporate ties. It’s a sorry state of affairs.
We have been down this road before.
Here is an example from the Tobacco companies and the debate about cancer. No
doubt you can also find plenty of material about how fossil fuel companies have
misled, even lied to us about fossil fuel use and climate change. You may find Cornell
using some of their same language.
Can we learn from these harmful experiences? Take a second look and scrutinize
the information and the way in which it is being presented. Remember too, the
centrality of the “Precautionary Principle,” where non-trivial harm is possible, do more
careful research before accepting the project, product, etc.
1953: “There is no proof that cigarette
smoking is one of the causes [of lung
cancer.]”
In the 1950s, extensive studies from the United Kingdom and
the United States
While it wasn’t the first time the correlation was
explored, the public began to worry.Even researchers working
for the tobacco industry appeared interested in the link. In a
1953 , one researcher noted
that clinical data supported the theory that cigarettes could be
cancer-causing.The tobacco industry had to respond to
pointed to smoking as a likely cause of lung
cancer
confidential report for RJ Reynolds
1952 ad for Camel cigarettes
reassure existing and potential
customers. In 1954, tobacco
companies in the U.S. released
the “Frank Statement to Cigarette
Smokers.” In the piece, the
tobacco companies denied the
link to cancer, stating: “We
believe the products we make
are not injurious to health.” They
sought to cast doubt on the
independent studies’ findings
related to lung cancer, saying
There is no proof that cigarette
smoking is one of the
causes.” ,
however, that tobacco companies
knew by the mid-1950s that their
products were linked to cancer
and were addictive.
Regi Teasley
Ithaca, NY
Protect what is left, recover what is lost of the fair earth.
William Morris, “Art and the Beauty of the Earth.” 1881
Research suggests
Subject: The list of synthetic turf on Cornell campus, and Failing TenCate Turf
March 17, 2025
Dear Town of Ithaca Planning Board Members,
Cornell University is on track to have at least 9 synthetic turf fields—six existing, two under
construction, and one proposed—plus at least one more planned at Game Farm Road
according to the planning board discussions. Please find the list in the attached PDF.
Without a legally binding Generic Environmental Impact Assessment (GEIS), even more could
follow. Cornell claims they will limit the number of Game Farm Road Site synthetic turf
only" to 3, in the recent planning board presentations and documents. However, the university
retains the power to expand at will without the binding GEIS. Their own 2015 document shows
plans for six synthetic turf fields at the Game Farm Road site—bringing the total potential
projected number of synthetic turf fields on campus to 12.
This isn’t only a local issue—it’s part of a larger crisis where corporate interests override
science and public health.
See the recent Guardian article on microplastics' effect on crop production and global
food supply.
https://www.theguardian.com/environment/2025/mar/10/microplastics-hinder-plant-photosynthes
is-study-finds-threatening-millions-with-starvation
Peer-reviewed study referenced in the article:
https://www.pnas.org/doi/abs/10.1073/pnas.2423957122
You may also find this 1-min video of failing TenCate turf in San Jose, California, from February
4, 2025, showing turf blades disintegrating only after 3 months of use, relevant for your decision
for the SEQR determination. From the way it looks, stormwater filtration seems clearly
insufficient for microplastics mitigation, as they do not seem to go through the drain. TenCate is
the synthetic turf of choice by Cornell University for the field hockey field.
Below are some photos from the video.
Very little debris seem to go through the drain and the vast majority stays on the ground.
Emily Jernigan
Zero Waste Ithaca
Treasurer
Updated List of Synthetic Turf on Cornell University Campus as of March 11, 2025
Map:
https://www.google.com/maps/d/u/1/edit?mid=1Vyg67BRoVsBxoQcd_m7Np4nsAdvN4PM&us
p=sharing
Cornell University is currently the largest source of synthetic turf microplastic pollution in
Ithaca, with 8 existing, proposed, or under-construction synthetic turf fields. Cornell
University is on track to have at least 9 synthetic turf fields—five existing, two under
construction, one proposed, and at least one more planned at Game Farm Road - and
potentially more. In comparison, Ithaca College has two, the Ithaca City School District has
one, the Groton School District has one, and the Lansing School District has a proposed field still
under debate.
Cornell’s Long Range Vision Plan (April 2024) proposes five additional fields around Game
Farm Road (see screenshot below with added markings). In its February 18 presentation to the
Town Planning Board, Cornell claimed there would be “only three” of them at the Game Farm
Road site would be synthetic turf. However, without a General Environmental Impact
Statement (GEIS), there is no legal mechanism to hold them accountable to this claim,
leaving them free to change course.
At the January 7 and March 4 Town Planning Board meetings, Cornell attempted to discredit
Zero Waste Ithaca’s submissions and bibliography by demonstrably misrepresenting science.
They dismissed ZWI members' estimates of synthetic turf expansion on Cornell campus and
public concerns as "untruths" and even accused us of spreading lies. We categorically reject
these baseless claims. Our numbers are grounded in publicly accessible data, and our goal
remains the same: to expose the environmental justice consequences of synthetic turf
proliferation and demand transparency and accountability from Cornell University by demanding
cooperation with GEIS.
From page 7 of Cornell University: Game Farm Road Athletic Complex Facilities Master Plan
Ithaca, NY: Cornell University, June 2015), the plan originally included 6 synthetic turf fields
at the Game Farm Road site. This would have brought the total number of synthetic turf
fields on Cornell's campus to 12. Cornell now claims there will be “only” three synthetic turf
fields at the Game Farm Road site in an obscure Town Planning Board document, but without a
General Environmental Impact Statement (GEIS), there is no guarantee that Cornell will
adhere to this projection. From
https://fcs.cornell.edu/sites/default/files/imce/site_contributor/Dept_University_Architect_and_C
ampus_Planning/documents/Campus_Planning/Game%20Farm%20Road%20Athletic%20Comp
lex%20Facilities%20Master%20Plan.pdf
Currently Existing Synthetic Turf Fields:
1. Hoy Field (2007) – Baseball
Demolished in 2023, but as of March 11, 2025, Cornell University still lists it as an
existing facility. This outdated information on Cornell’s website led to an incorrect count
in our earlier submission.)
https://en.wikipedia.org/wiki/Hoy_Field
https://cornellbigred.com/facilities/hoy-field/5
2. Schoellkopf Field (1979) – Football, Lacrosse, etc.
https://en.wikipedia.org/wiki/Schoellkopf_Field
3. North Campus Turf Field (2022) – Recreation
https://scl.cornell.edu/recreation/north-campus-turf-field
https://news.cornell.edu/stories/2022/08/cornell-welcomes-students-marks-milestone-resi
dential-life
4. Booth Field (2023) – Baseball, Game Farm Road
https://cornellbigred.com/facilities/booth-field/2132
5. Niemand-Robison Softball Field (1998) – Softball
https://cornellbigred.com/facilities/niemand-robison-softball-field/13
6. Ramin Multipurpose Room – Indoor synthetic turf, Bartels Hall
https://cornellbigred.com/facilities/ramin-multipurpose-room/73
Proposed/Under Construction Synthetic Turf Fields:
7. Meinig Fieldhouse (Under Construction) – Indoor synthetic turf, planned to use crumb
rubber
https://www.cityofithaca.org/DocumentCenter/Index/1647
8. Adjacent Synthetic Turf Field to Meinig Fieldhouse (Under Construction) –Name
unknown, described as using "PFAS-free" organic infill, though many questions and
concerns raised in previous public comments remain poorly answered by Cornell
https://www.cityofithaca.org/DocumentCenter/Index/1647
9. Field Hockey Field, Game Farm Road (Currently Proposed) – no infill
https://lfweb.tompkins-co.org/WebLink/Browse.aspx?id=357756&dbid=9&repo=TownO
fIthaca&cr=1
Five additional fields proposed around Game Farm Road in Cornell’s “Long Range
Vision Plan” (April 2024, Page 6) submitted to the City and Town Planning Boards, of
which “only” three will be synthetic turf. There is a plan for at least one more synthetic
turf at the site, according to Cornell’s recent submissions to the Town Planning Board in
February 2025. There could be even more without legally binding GEIS.
https://www.dropbox.com/scl/fi/fg4n5fanrv3o2xwf6dli5/PB-packet-5-21-24-Meinig-SEQ
R-Segmentation-Long-Range-Vision.pdf?rlkey=1lq70pmm1q3ie7s4yn5z073my&st=87q
gj6qr&dl=0
From:
To:
Subject:
Attachments:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning; pbstaff@cityofithaca.org;
Submission of Two Bibliographies on Synthetic Turf Impacts
Selection from ZWI Synturf Bibliography for Field Hockey Field on Game
Farm Road Site-1.pdf
3/18/2025 8:07:52 AM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town of Ithaca Planning Board Members,
We are submitting two bibliographies for the Town of Ithaca Planning Board's
review regarding synthetic turf and its environmental and health impacts. These
materials provide comprehensive, science-based evidence that contradicts claims made
regarding the proposed synthetic turf field at Game Farm Road and the broader
concerns surrounding artificial turf use.
1. Comprehensive Bibliography (162 pages, Updated March 17, 2025)
This fully categorized, partially annotated bibliography has been meticulously
compiled over the past year by volunteers and allies across the country. It presents a
multifaceted analysis of synthetic turf, covering:
Plastic life cycle impacts
PFAS in all components of artificial turf system and industry's misleading
PFAS-free’ claims
Independent PFAS test results
Toxicity beyond PFAS: heavy metals, plasticizers, and other chemicals
Synthetic turf fiber loss and microplastic pollution
Health risks: injuries, heat exposure, air emissions
Environmental justice impacts throughout plastic lifecycle: plastic pollution
in urban and rural communities
Disposal issues and the failure of plastic recycling at scale
Legislative bans, restrictions, moratoriums, lawsuits, and investigative
journalism
Cost comparisons and heat island effects between natural grass and
artificial turf
Video documentation of visible synthetic turf degradation and microplastic
pollution, relevant webinars with experts
Despite the overwhelming body of evidence, Cornell’s submission to the Town of
Ithaca Planning Board selectively excluded or downplayed key findings by
focusing only on peer-reviewed studies while disregarding highly relevant
materials from independent experts, nonprofit organizations, and investigative
journalists.
We strongly urge Town Planning Board members to review this bibliography
thoroughly, or at the very least skim through its key sections to understand the depth
and breadth of the issue. This collection represents a year’s worth of dedicated
research, carefully selected and organized, and it deserves serious consideration.
2. Selected Bibliography on Turf Fibers and "PFAS-free" Claims (15
pages, Updated March 17, 2025)
This second bibliography focuses specifically on synthetic turf fibers, backings and
shockpads, particularly regarding the Game Farm Road field, which has been
described as “safe” in part due to the absence of crumb rubber infill.
However, as the scientific evidence clearly shows, synthetic turf blades and backings
are significant sources of toxic microplastic pollution, including:
PFAS contamination in turf fibers
Microplastic and chemical leaching from synthetic grass blades
Long-term degradation of turf fibers, contributing to environmental
pollution
Cornell’s submission has framed the absence of crumb rubber infill as evidence that
there are no significant concerns with the proposed field. However, this
misrepresents the broader body of research showing that turf fibers and backings
themselves contain hazardous chemicals and contribute to ongoing environmental
pollution. The evidence compiled in this 13-page fully annotated bibliography
challenges these claims and provides clear scientific proof that synthetic turf—
regardless of infill—poses serious environmental and health risks.
Cornell’s Handling of Scientific Studies
Cornell’s submission to the Town Planning Board excluded or downplayed important
studies that challenge the claims made in favor of synthetic turf. For example:
Key studies were omitted or misrepresented in the 39-page submission
despite clear relevance.
Some studies were dismissed as “non-peer-reviewed” even when they
contained credible scientific data.
Other studies were labeled “not turf-specific” despite clear findings on
synthetic turf pollution.
Certain studies were included in name only, with just an abstract copied into
the submission rather than an engagement with the findings.
We find it ironic that Cornell representatives, such as Kimberly Van Leeuwen
formerly Kimberly Michaels), have told the Town Planning Board to “look at the
original studies.” in the March 4 Town Planning Board meeting. We strongly
encourage board members to do exactly that, because these studies expose patterns
of selective omission and downplaying of environmental and public health risks.
Conclusion & Call to Action
The Town Planning Board has a responsibility to critically evaluate all available
evidence before making decisions that will impact the local environment and public
health. Given the significant body of research indicating environmental and health
concerns, these risks deserve thorough and independent consideration.
We urge board members to:
1. Thoroughly review the 15-page Selected Bibliography focused on turf fibers
and backings.
2. Examine the 162-page Comprehensive Bibliography to understand the broader
issue.
3. Consider how certain studies have been selectively omitted or dismissed—
specific examples are highlighted in our materials.
Final Note
The synthetic turf industry has long used selective data and marketing to downplay
concerns. We hope that the Town Planning Board will take an independent, science-
based approach, rather than relying solely on the claims made in favor of synthetic
turf.
We respectfully ask the Town Planning Board to approach these materials with the
critical scrutiny they deserve and to recognize that the Game Farm Road field
poses serious environmental risks—even without crumb rubber infill.
In compiling the Selected Bibliography, we specifically examined how Cornell
University represented and omitted key materials related to turf blade
degradation, PFAS testing, and the industry’s claims of PFAS-free synthetic turf
in their 39-page submission to the Town Planning Board. However, this is only a
fraction of their submission that we had time to analyze as volunteers. While this
selection highlights clear patterns of omission and misrepresentation, it reflects a
broader ongoing pattern that we have already documented in previous submissions
regarding CY Jim, Zuccaro, EPA reports, and on plastic recycling numbers. We
respectfully submit this as further evidence of the systematic dismissal of key
findings and urge the Planning Board to review these materials with scrutiny.
Hereby, we have submitted this evidence for your review, ensuring that the record
reflects these critical findings, which you are choosing to disregard as you move
forward with a Negative Declaration.
Yayoi Koizumi
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
1
Toxic Chemicals and Microplastic
Pollution in Synthetic Turf Blades,
Backings, and Runoff Filtration
Selected Materials for the Call on GEIS for the Game Farm Road Site from:
The Case Against Artificial Turf Expansion at Cornell: A Zero Waste Ithaca
Bibliography, Updated March 16. 2025
https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-
s_4bfbmO26R-Q/edit?tab=t.0
This bibliography focuses on the toxic chemicals and microplastic pollution associated with artificial turf
blades, backings, and runoff filtration—not just infill. Cornell University has attempted to dismiss
environmental and health concerns by claiming that because the planned field hockey field does not
include crumb rubber infill, it poses no risks. However, research shows that synthetic turf blades and
backings contain and shed hazardous substances, including PFAS, phthalates, heavy metals, and
microplastics, which persist in the environment and pose health risks. The studies and reports compiled
here provide evidence that synthetic turf fields—regardless of infill—are a significant source of
microplastic pollution and chemical exposure.
Note on Bibliographic Items and Cornell's Omissions
Certain key sources in this bibliography have been misrepresented, dismissed, or entirely omitted in
Cornell’s 39-page table submitted to the Town of Ithaca Planning Board in their February 21, 2025
submission of “Supplemental Materials Submission.” Their categorization tactics include:
Omission – Conveniently left out from Cornell’s submission despite relevance.
Dismissal as "Non-Peer Reviewed" – Used as a reason to disregard findings.
Misrepresentation – Included only as a copied abstract with no discussion to repudiate
study findings or misrepresent findings.
Dismissal as "Not Turf Specific" – Ignoring connections to artificial turf pollution.
This selection presents a full, unfiltered view of the scientific literature, including materials Cornell has
attempted to discredit. While we have not had time to analyze all omissions from our 150+-page
bibliography, this document highlights key sources relevant to the Planning Board’s review of the
infill-free, water-based field hockey field at the Game Farm Road site. These materials directly counter
Cornell’s claims by demonstrating that pollution from artificial turf extends beyond infill and includes
microplastic shedding, PFAS contamination, and toxic chemical leaching from the blades and backings
themselves.
2
Toxic Substances and Microplastic Shedding from
Artificial Turf Blades and Backings
Abel, David. "Toxic Chemicals Are Found in Blades of Artificial Turf." Boston Globe, October
9, 2019. Available at
https://www.bostonglobe.com/metro/2019/10/09/toxic-chemicals-found-blades-artificial-t
urf/1mlVxXjzCAqRahwgXtfy6K/story.html.
California Department of Toxic Substances Control. Background Document on Candidate
Chemicals in Artificial Turf. Safer Consumer Products Program, California
Environmental Protection Agency, August 2024.
https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Cand
idate-Chemicals-in-Artificial-Turf.pdf.
The California Department of Toxic Substances Control (DTSC) released the
Background Document on Candidate Chemicals in Artificial Turf" in August 2024. This
document examines the presence of per- and polyfluoroalkyl substances (PFASs),
ortho-phthalates, and other additives in artificial turf blades and backing. It highlights
concerns regarding potential human and environmental exposures to these chemicals and
seeks public input to address data gaps and inform future regulatory actions.
In response to this call for public comments, Diana Conway from Safe Healthy Playing
Fields and the Silent Spring Institute submitted a letter expressing concerns about the
presence of PFAS and other toxic chemicals in artificial turf. They urged the DTSC to
take regulatory action to protect public health and the environment from hazardous
exposures associated with synthetic playing surfaces.
Following the public comment period, which concluded on September 30, 2024, the
DTSC held a virtual workshop on August 27, 2024, to discuss key findings and gather
additional input. The information collected from the workshop and public comments is
being used to prioritize candidate chemicals in artificial turf for potential regulation. As
of February 2, 2025, the DTSC is conducting further research to draft a
Product-Chemical Profile document for artificial turf containing PFAS. This ongoing
research aims to inform potential regulatory actions to mitigate adverse public health
and environmental impacts associated with these chemicals.
De Haan, William P., Rocío Quintana, César Vilas, Andrés Cózar, Miquel Canals, Oriol
Uviedo, and Anna Sanchez-Vidal. “The Dark Side of Artificial Greening: Plastic Turfs as
Widespread Pollutants of Aquatic Environments.” Environmental Pollution 334 (2023):
122094. https://doi.org/10.1016/j.envpol.2023.122094.
3
This Barcelona study found that up to 15% of the larger microplastic pieces in the
environment come from artificial turf blades. This significant fiber loss contributed to the
University of California, Santa Barbara's decision to choose natural grass over artificial
turf, supported by the California Coastal Commission, on December 13, 2023. De Haan's
presentation in a CHE webinar in September 2024 emphasized there must be more than
15% but there was no viable method available to test smaller particles.
Hann, S., C. Sherrington, O. Jamieson, M. Hickman, P. Kershaw, A. Bapasola, and G. Cole.
Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics
Emitted by (but Not Intentionally Added in) Products. Bristol, UK: Eunomia Research &
Consulting, 2018.
https://eunomia.eco/reports/investigating-options-for-reducing-releases-in-the-aquatic-en
vironment-of-microplastics-emitted-by-products/.
This report, commissioned by the European Commission, examines various sources of
microplastic pollution, including artificial turf fields. It estimates that a single synthetic
turf field loses 0.5 to 0.8% of its plastic blades annually, equating to approximately
2,000 to 3,000 pounds of microplastic pollution per field per year. This estimate,
significantly lower than a previous Danish study's 0.8 kg/m² loss rate, highlights the
ongoing and substantial contribution of synthetic turf fiber to environmental
microplastic contamination. The report provides direct evidence that plastic blade
fragmentation is an unavoidable and underestimated source of pollution.
Lauria, Mélanie Z., Ayman Naim, Merle Plassmann, Jenny Fäldt, Roxana Sühring, and
Jonathan P. Benskin. “Widespread Occurrence of Non-Extractable Fluorine in Artificial
Turfs from Stockholm, Sweden.” Environmental Science & Technology Letters. July 6,
2022. DOI: 10.1021/acs.estlett.2c00260
https://pubs.acs.org/doi/10.1021/acs.estlett.2c00260
Lauria et al. (2022) found that artificial turf fibers in Stockholm contain polymeric
PFAS, including fluoroelastomers and polytetrafluoroethylene (PTFE), which are highly
persistent and resistant to degradation. The study highlights that incineration is
ineffective at fully breaking down these compounds, potentially leading to the release of
toxic fluorinated byproducts such as hydrogen fluoride and perfluoroalkyl acids (PFAAs).
Additionally, artificial turf blades degrade over time, shedding PFAS-laden
microplastics that disperse into the environment, contributing to soil and water
contamination. Exposure to UV light, heat, and mechanical stress can break down
polymeric PFAS into smaller, more mobile and toxic perfluoroalkyl carboxylic acids
PFCAs), such as PFOA, which are known to bioaccumulate. The findings underscore
that artificial turf serves as a long-term source of PFAS pollution, with no viable
disposal method that prevents environmental contamination.
Mehmood, Tariq, and Licheng Peng. "Polyethylene Scaffold Net and Synthetic Grass
Fragmentation: A Source of Microplastics in the Atmosphere?" Journal of Hazardous
Materials 429 (May 2022): 128391. https://doi.org/10.1016/j.jhazmat.2022.128391
4
Mehmood and Peng explore the growing concern surrounding microplastics (MPs) in
urban atmospheres, particularly focusing on polyethylene (PE), which dominates
ambient MPs in China’s megacities. They investigate the sources of airborne PE, such as
scaffold netting and synthetic grass fiber/blades used in construction and land covering.
These materials, often made from recycled plastic and exposed to open air, are prone to
degradation and fragmentation, contributing to atmospheric pollution. The authors
emphasize the health risks associated with PE exposure in urban air and highlight the
need for regulation to mitigate these risks. This study offers insights into the overlooked
role of synthetic grass and construction materials as significant contributors to airborne
microplastics.
Mohammed, Atef MF, Inas A. Saleh, and Nasser M. Abdel-Latif. “Hazard Assessment Study
on Organic Compounds and Heavy Metals from Using Artificial Turf.” Heliyon 9, no. 4
2023). https://www.cell.com/heliyon/pdf/S2405-8440(23)02135-7.pdf.
The Egyptian study investigates the release of hazardous substances, including VOCs,
PAHs, and heavy metals, from artificial turf as affected by sunlight exposure. It monitors
VOC levels across different seasons and settings, including indoor and outdoor
environments. The findings indicate elevated VOC levels during warmer seasons and
highlight higher exposure risks for younger age groups (7–15 years) compared to others.
While the hazard index (HI) values suggest no immediate non-carcinogenic risk, the
study reports a high probability of cancer risk (R) for various age groups, particularly
children, when exposed to artificial turf on football fields.
Cornell falsely dismissed Mohammed et al. (2023) in their table (Item 81) as a study
solely on tire-derived crumb rubber (TDCR) when it actually examined VOCs, PAHs,
and heavy metals from all components of synthetic turf under different environmental
conditions. They selectively cited the study’s non-carcinogenic risk (HI < 1) while
omitting its key finding that the carcinogenic risk (R) exceeded safety thresholds,
particularly for children aged 7–15. Cornell also ignored the study’s clear evidence that
VOCs increase significantly in warm weather, making exposure risks higher during
peak usage seasons. Their misrepresentation distorts the study’s conclusions, downplays
health risks, and falsely narrows its scope to avoid acknowledging the cancer risks and
broader toxicity of synthetic turf.
Persellin, Ketura. “New Studies Show PFAS in Artificial Grass Blades and Backing.”
Environmental Working Group. October 29, 2019.
https://www.ewg.org/news-insights/news/new-studies-show-pfas-artificial-grass-blades-a
nd-backing.
Ryan-Ndegwa, Sebastian, Reza Zamani, and Tanimola Martins. "Exploring the Human Health
Impact of Artificial Turf Worldwide: A Systematic Review." Environmental Health
Insights, first published online December 17, 2024.
https://doi.org/10.1177/11786302241306291.
This systematic review examines the potential human health risks associated with
5
artificial turf, focusing on polycyclic aromatic hydrocarbons (PAHs), heavy metals, and
rubber additives. Hazardous chemical concentrations were detected in artificial turf
fibers and crumb rubber infill, necessitating further research.
Simpson, Thomas J., and Robert A. Francis. “Artificial Lawns Exhibit Increased Runoff and
Decreased Water Retention Compared to Living Lawns Following Controlled Rainfall
Experiments.” Urban Forestry & Urban Greening 63 (2021): 127232.
https://doi.org/10.1016/j.ufug.2021.127232.
This study examines the hydrological impacts of artificial (synthetic polymer) grass
compared to living grass using controlled rainfall experiments. It finds that artificial
grass, especially with longer pile heights, produces greater runoff and sheds plastic
thatch and fibers, posing environmental concerns; living grass demonstrates superior
water retention and drainage control.
Wittenberg, Ariel and E. A. Crunden. “EPA-Linked Consultant Undercuts Agency’s PFAS
Concerns.” Politico E&E News. December 8, 2021.
https://www.eenews.net/articles/epa-linked-consultant-undercuts-agencys-pfas-concerns.
Laura Green, an industry toxicologist promoting artificial turf fields has repeatedly
cited her work for EPA while downplaying the risks of “forever chemicals” while
showing the evidence the chemicals are used to produce plastic grass blades, making
controversial claims often at odds with the agency’s own findings.
Zhang, Xiaoran, Yupeng Gu, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, Ziyang
Zhang, Chaohong Tan, Yu Wang, and Haiyan Li. “Occurrence and Risk Assessment of
PAHs from Athletic Fields under Typical Rainfall Events.” Water Science & Technology
87, no. 9 (2023): 2159–2171. https://doi.org/10.2166/wst.2023.092.
This study examines the release of PAHs from various athletic field surfaces during
rainfall, finding significantly higher PAH concentrations in runoff from artificial turf
compared to other surfaces. While PAHs are often associated with crumb rubber infill,
research has shown that PAHs can also be present in turf blades and backings due to
manufacturing additives, plasticizers, recycled plastics and carbon black. This is
critical because Cornell’s claim of using plant-based infill for some outdoor turf does not
address the contamination risks posed by the synthetic turf itself.
Zuccaro, Philip, James Licato, Emily A. Davidson, David C. Thompson, and Vasilis
Vasiliou. “Assessing Extraction-Analysis Methodology to Detect Fluorotelomer Alcohols
FTOH), a Class of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), in Artificial
Turf Fibers and Crumb Rubber Infill." Case Studies in Chemical and Environmental
Engineering 7 (2023): 100280. https://doi.org/10.1016/j.cscee.2022.100280.
This pilot study developed and applied an adapted extraction-analysis method to detect
fluorotelomer alcohols (FTOHs), a class of PFAS, in artificial turf fibers and crumb
6
rubber infill. Results revealed the presence of 8:2 FTOH at concentrations of 300 ng/g
in turf fibers and 110 ng/g in crumb rubber, emphasizing the need for further research
into PFAS in artificial turf components.
On “PFAS-Free” Claim by Synthetic Turf Manufacturers
Gambacorta, David and Laker, Barbara. “City Officials Believed a New South Philly Turf
Field was PFAS-Free. Not True, Experts Say.” The Philadelphia Inquirer. February 23,
2024.
https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-turf-field-murph
y-recreation-20240223.html
This article is a part of the multi-year investigative journalism on synthetic turf by The
Philadelphia Inquirer. The industry’s “PFAS-free” claims turned out to be false for a new
Philadelphia turf field.
Gearhardt, Jefferey, MS. Director of Research, The Ecology Center, Ann Arbor, MI. Letter to
Portsmouth, NH City Council and Director of Finance and Administration. 1 Jun 2020.
https://nontoxicdovernh.files.wordpress.com/2020/06/june1_portsmouthpfas.pdf
This letter, addressed to the Portsmouth City Council, discusses the challenges of
accurately testing for PFAS in synthetic turf fibers. The author reports that, despite
claims of PFAS-free turf, their research detected fluorine, a potential indicator of PFAS,
in all nine synthetic turf fibers tested. One sample from the Tom Daubney Field in
Portsmouth showed 79 parts per million (ppm) of fluorine, indicating the likely presence
of PFAS, despite PFAS-free claims. The letter highlights concerns about the inadequacy
of EPA Method 537.1, which is designed for water testing and does not detect all possible
PFAS chemicals. The author advocates for more comprehensive testing methods to ensure
accurate PFAS detection in synthetic turf.
Kristen Mello, MS. Email to Mayor Eachern, City of Portsmouth, NH Regarding Additional
PFAS Testing of FieldTurf Vertex, Schmidt Shock Pad and SafeShell infill installed June
2021. July 5, 2022.
https://nontoxicdovernh.wordpress.com/wp-content/uploads/2022/07/wraft-pfas-portsmo
uthletter-5july2022.pdf
The letter by Kristen Mello, M.Sc. in Analytical Chemistry, addresses concerns about
PFAS contamination in synthetic turf materials, specifically referencing testing results
7
from Portsmouth, New Hampshire. It details the findings of both known and unidentified
PFAS compounds in various components of artificial turf, such as the Field Turf carpet,
Schmitz Foam ProPlay pad, and Greentech Safeshell infill, with results showing the
presence of multiple toxic chemicals including GenX, HFPO-DA, and other
proprietary PFAS. These findings contradict industry claims that certain turf products
are "PFAS free." The letter highlights the potential risks to public health and the
environment, emphasizing the need for strict oversight and accountability from city
officials, especially in holding contractors responsible for their promises of PFAS-free
materials. In light of EPA advisories that drastically reduce acceptable PFAS exposure
levels, the letter urges city officials to take every measure to limit contamination and
protect taxpayers from future costs related to turf field replacement, remediation, and
disposal.
Lauria, Mélanie Z., Ayman Naim, Merle Plassmann, Jenny Fäldt, Roxana Sühring, and
Jonathan P. Benskin. “Widespread Occurrence of Non-Extractable Fluorine in Artificial
Turfs from Stockholm, Sweden.” Environmental Science & Technology Letters. July 6,
2022. DOI: 10.1021/acs.estlett.2c00260
https://pubs.acs.org/doi/10.1021/acs.estlett.2c00260
Lauria et al. (2022) found that artificial turf fibers in Stockholm contain polymeric PFAS,
including fluoroelastomers and polytetrafluoroethylene (PTFE), which are highly
persistent and resistant to degradation. The study highlights that incineration is
ineffective at fully breaking down these compounds, potentially leading to the release of
toxic fluorinated byproducts such as hydrogen fluoride and perfluoroalkyl acids (PFAAs).
Additionally, artificial turf blades degrade over time, shedding PFAS-laden
microplastics that disperse into the environment, contributing to soil and water
contamination. Exposure to UV light, heat, and mechanical stress can break down
polymeric PFAS into smaller, more mobile and toxic perfluoroalkyl carboxylic acids
PFCAs), such as PFOA, which are known to bioaccumulate. The findings underscore
that artificial turf serves as a long-term source of PFAS pollution, with no viable
disposal method that prevents environmental contamination.
Cornell misrepresents Lauria et al. (Item 37 in the table) by selectively emphasizing that
the study found low levels of extractable PFAS while ignoring its broader environmental
concerns. While the study states that most fluorine in artificial turf exists in polymeric
form and does not pose an imminent risk to users, Cornell downplays Lauria’s warnings
about long-term environmental contamination, including microplastics and the unknown
effects of fluoropolymer degradation. Additionally, Cornell overlooks Lauria’s findings
on the potential risks associated with artificial turf’s disposal, as landfilling and
incineration may release PFAS into the environment. By focusing solely on the low
bioavailability of PFAS in the short term, Cornell mischaracterizes the study’s overall
conclusions, which explicitly call for further research into the long-term impacts of
PFAS-containing artificial turf.
8
Rudiman, M, LaRossa, S. Response to Questions, Synthetic Turf Installation, Portsmouth,
NH. Weston and Sampson Email Communication to S Woodward and P Rice, City of
Portsmouth, NH with Response from Manufacturer FieldTurf (a Tarkett Company)
Regarding Claims of PFAS Free Synthetic Turf. November 5, 2021.
https://www.dropbox.com/scl/fi/pr5t7p34hlndd1lk3tlyj/PFAS_Questions-Letter-Portsmou
th-11.05.21.pdf?rlkey=7tk69p1vaqx7x6r0bc9fb7eot&st=t443mr9c&dl=0
Weston & Sampson Engineers, Inc. respond to questions from Diana Carpinone
regarding the synthetic turf field installation in Portsmouth, New Hampshire. The letter
confirms that FieldTurf, the manufacturer of the synthetic turf, incorrectly claimed its
product was "Fluorine Free." While the product met the project’s specifications for
being PFAS-free based on existing standards, the letter acknowledges the possibility of
fluorine presence in the natural environment and emphasizes the limitations of current
testing technologies. The company conducted PFAS testing using EPA Method 537.1, but
did not verify whether specific PFAS polymers, such as PTFE or PVDF, were used. This
correspondence highlights the complexities and gaps in testing for fluorine-based
compounds in synthetic turf materials.
Toxic Use Reduction Institute. “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial
Turf Carpet.” February 2020.
https://www.turi.org/publications/pfas-in-artificial-turf-carpet/
This nonprofit report addresses the challenges in testing for PFAS (Per- and
Polyfluoroalkyl Substances) in artificial turf and other solid materials. It highlights the
difficulty of detecting the full range of PFAS due to the vast number of chemicals in the
class and the limitations of current testing methods, which are primarily developed for
water rather than solid materials. The report suggests that the industry's claims of
PFAS-free" products can be misleading, as the absence of specific PFAS in tests does
not confirm the absence of all PFAS. The use of Total Fluorine Analysis and TOP
assays is recommended for a broader understanding of PFAS presence. Additionally,
the report cites research that detected PFAS in artificial turf fibers and backing, including
both short-chain and long-chain PFAS, raising concerns about their environmental
impact and health risks.
Whitehead, Heather D. Development of Analytical Methods for Highly Selective and Sensitive
Analysis of Compounds Relevant to Human Health and the Environment. PhD diss.,
University of Notre Dame, 2023.
https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Se
lective_and_Sensitive_Analysis_of_Compounds_Relevant_to_Human_Health_and_the_
Environment/24869502?file=43760148. Dropbox full pdf backup:
https://www.dropbox.com/scl/fi/73xaku3dwi0jjtgamnoe3/WhiteheadHD042023D-1.pdf?r
lkey=y871tnevcqk4r0kwlzd42qhke&st=ioc6xn65&dl=0.
This dissertation provides critical evidence of PFAS contamination in artificial turf
blades, analyzing 27 samples using multiple methods. PFAS were detected in all
samples, with a median concentration of 5.1 ng/g and a maximum of 41.7 ng/g, while
9
organic fluorine measurements indicated the presence of fluorinated polymer
processing aids. This is arguably the most in-depth scientific study on PFAS in artificial
turf blades that Cornell University conveniently omits from their 39-page table detailing
our bibliographic entries to discredit them. These findings confirm that PFAS are
embedded in synthetic turf materials, raising concerns about long-term environmental
and human exposure risks.
Cornell dismisses critical research by Peaslee & Whitehead (2024) as
non-peer-reviewed" (line item 85) despite its direct relevance to PFAS contamination
from synthetic turf runoff. At the same time, they conveniently fail to include Whitehead’s
2023 Ph.D. dissertation, which is arguably the most in-depth scientific study to date on
PFAS in synthetic turf blades. Whitehead (2023) analyzed 27 artificial turf samples,
detecting PFAS in every single one using multiple analytical methods, with
concentrations ranging from 5.1 ng/g to 41.7 ng/g. The omission of this study is
indefensible and further underscores their selective cherry-picking of studies that align
with their predetermined conclusions.
In addition to peer-reviewed research, independent testing has repeatedly found PFAS in
both synthetic turf blades and backings, contradicting manufacturers’ claims of
PFAS-free" products. These independent analyses suggest that fluorinated polymer
processing aids (fPPAs), used in plastic extrusion, likely introduce PFAS into turf
materials. The industry's claims of PFAS-free certification remain unverified by
independent scientific scrutiny.
Cornell’s approach demonstrates a pattern of misrepresentation and omission,
selectively dismissing robust studies that document PFAS contamination in synthetic turf
while inflating the credibility of studies that support their narrative. The exclusion of
Whitehead (2023), in particular, is a glaring omission that calls into question the
integrity of their entire submission.
10
Turf Blade Deterioration Videorecordings Documented by
Grassroots Volunteers Around the US
Bond, Pamela. John Mise Park, San Jose, California: TenCate Pivot. February 4, 2025.
https://www.dropbox.com/scl/fi/naamke5hbco8pt82zw843/TenCate-Pivot-turf-John-Mise
Park-San-Jose-CA-only-3-months-after-installation-video-by-Pam-Bond-of-Los-Gatos-
CA-Feb-4-2025.qt?rlkey=fz31t8t2pmx6sjtxgwee5oyt1&st=hvktv3mn&dl=0
TenCate is Cornell’s chosen synthetic turf manufacturer for the planned field hockey field
on Game Farm Road. This one-minute video documents visible fragmentation and failure
of TenCate's synthetic turf blades at John Mise Park in San Jose, California, occurring
just three months after installation. The footage demonstrates turf blades breaking into
smaller fibers, which disperse into the environment rather than being captured by the
filtration system intended to prevent microplastic pollution. Recorded on February 4,
2025, by Pamela Bond, a resident of Los Gatos, California, concerned about
environmental impacts of synthetic turf.
11
Farber, Amanda. Synthetic Turf Fields Are Failing. YouTube video, 5:26. September 2018.
https://www.youtube.com/watch?v=iV-Mh_q0gMI&t=4s.
Amanda Farber, a member of Safe Healthy Playing Fields, documents the deterioration
of synthetic turf fields in Washington, D.C., with footage from August and September
2018. The video highlights the visible breakdown of artificial grass blades and infill
displacement, underscoring concerns about the durability and safety of these fields.
Safe Healthy Playing Fields. Artificial Turf Hearing - Dr. Laura Green. YouTube Video. April
13, 2021. https://youtu.be/A8OLBfWmt7g?si=DfSEWqdt6YemE-ER
Safe Healthy Playing Fields. [Turf Blade Deterioration at Rotch Field at Emerson College,
Boston.] July 10, 2021.
https://www.facebook.com/share/v/19zktsiY6Q/?mibextid=wwXIfr
Safe Healthy Playing Fields. [Turf Blade Deterioration at Walter Johnson High School in
Bethesda, MD.] July 26, 2019.
https://www.facebook.com/share/v/19zApLLE6k/?mibextid=wwXIfr
Safe Healthy Playing Fields. [Turf Blade Deterioration at MIT, Boston.] July 25, 2021.
https://www.facebook.com/share/v/1DxUuEDeTE/?mibextid=wwXIfr
12
Woelke, Dianne. [Turf Blade Deterioration at Villa Parke]. Filmed June 2024 at Villa Parke,
Pasadena, CA.
https://www.dropbox.com/scl/fi/55qmokb3cgpqebcnwy95m/73983745599__0E158EA2-7
E22-467E-976A-065BF7A21B51.mov?rlkey=k04cfu2480126zzuvn0kitpgy&st=ffep4pi4&
dl=0.
In this video, Dianne Woelke, a board member of Safe Healthy Playing Fields, documents
the degradation of 1.5 year-old FieldTurf brand artificial turf at Villa Parke in
Pasadena, California. The footage, captured in June 2024, highlights issues such as turf
blades detaching and infill displacement, raising concerns about the durability and safety
of synthetic playing surfaces.
Filtration of Runoffs
Brown, Erina, Anna MacDonald, Steve Allen, Deonie Allen. “The Potential for a Plastic
Recycling Facility to Release Microplastic Pollution and Possible Filtration Remediation
Effectiveness.” Journal of Hazardous Materials Advances. May 2023.
https://doi.org/10.1016/j.hazadv.2023.100309
The UK study shows that the filtration system installed at the plastic recycling facility is
effective at removing the majority of microplastics larger than 5µm, with particularly high
removal efficiencies for those larger than 40µm. However, the filtration is ineffective at
removing microplastics smaller than 5µm, which are subsequently discharged into the
environment. The recommendation for additional filtration indicates that the current
system does not adequately address all microplastic pollution, particularly the smaller
particles. Chand, Rupa, Lucian
Iordachescu, Frida Bäckbom, Angelica Andreasson, Cecilia Bertholds, Emelie Pollack,
Marziye Molazadeh, Claudia Lorenz, Asbjørn Haaning Nielsen, and Jes
Vollertsen. "Treating Wastewater for Microplastics to a Level on Par with Nearby Marine
Waters." Water Research 256 (June 1, 2024). https://doi.org/
10.1016/j.watres.2024.121647. The Swedish study
conducted at a wastewater treatment plant focuses on the retention of microplastics ranging from
10 to 500 µm. The plant's filtration system, which achieved a 99.98% removal
efficiency, utilizes a combination of mechanical, biological, and chemical treatments, and
includes rapid sand filtration with pore sizes ranging from 15 to 30 µm—
much smaller than the 212-micron pore size for Meinig “Fieldhouse” Project and 25-
micron for Field Hockey Field on Game Farm Road Site proposed by Cornell’s filtration
system. Their success is due to the integration of multiple processes, rather than relying
solely on mechanical filtration. However, it's
important to note that this study did not target or remove sub-micron nanoparticles, which the
Korean TENG study addressed using an electrophoretic method (Park et
al., 2022, below). 25-212-micron pore sizes would allow many smaller microplastics and essentially
all nanoplastics to pass through unfiltered. This is a
13
significant limitation, especially given the concerns about these tiny particles in aquatic
environments. Systems designed to remove such small particles, like the TENG system,
operate on entirely different principles because traditional filtration alone isn’t enough
at those scales.
Cornell's system would primarily capture larger particles and debris only in runoffs -
assuming water run-offs will all go through their filtration system - but would not
address the growing problem of microplastic and nanoparticle pollution, which is
where the Korean TENG system proves more effective for smaller-sized contaminants
Park, et al, 2022, below).
Global Market Insights, Inc. PVDF Membrane Market Size - By Material Type (Hydrophilic
PVDF Membrane, Hydrophobic PVDF Membrane), By Technology (Microfiltration (MF)
PVDF Membrane, Ultrafiltration (UF) PVDF Membrane, Nanofiltration (NF) PVDF
Membrane), By End-use & Forecast, 2023 – 2032. Report ID: GM16415. Published
August 2023. Accessed January 26, 2025.
https://www.gminsights.com/industry-analysis/pvdf-membrane-market.
This report highlights the widespread use of polyvinylidene fluoride (PVDF) membranes
in filtration systems, particularly in microfiltration and ultrafiltration technologies.
PVDF's exceptional durability, chemical resistance, and efficiency in filtering
contaminants contribute to its prevalence in water treatment applications. The report
estimates the global PVDF membrane market value at $790 million in 2022, projected to
exceed $1.6 billion by 2032. However, as a fluoropolymer, PVDF is associated with
PFAS (per- and polyfluoroalkyl substances), raising concerns about potential
environmental and health impacts despite its utility in filtration systems.
Park, Byung-Geon, Cheoljae Lee, Young-Jun Kim, Jinhyoung Park, Hyeok Kim,
Young Jung, Jong Soo Ko, Sang-Woo Kim, Ju-Hyuck Lee, Hanchul Cho. “Toxic
Micro/Nano Particles Removal in Water via Triboelectric Nanogenerator.” Nano
Energy, 2022; 100: 107433 DOI: https://doi.org/10.1016/j.nanoen.2022.107433
This study demonstrates a new approach using a triboelectric nanogenerator (TENG) for
removing micro- and sub-micron nanoparticles from water smaller than 1µm, leveraging
an electrophoretic process driven by the electric field generated by the TENG. Even
with the use of advanced materials like the porous-pyramid polydimethylsiloxane PDMS)
layer, the system achieved only a 21.4% removal rate. While this method represents
progress in the field of microplastic remediation, it underscores significant limitations
in terms of efficiency and cost-effectiveness for large-scale applications. Cornell'
s mechanical filtration proposals suggest using filters with its huge pore sizes of 25-
212 microns, which are considerably larger than those used in the TENG system. Given
that this advanced TENG system with smaller pores and electrical enhancement was
only able to capture a fraction of microplastic pollutants, serious concerns arise about
the efficacy of the filtration methods proposed by Cornell. It is questionable whether
such a method will adequately address micro and nano plastic contamination
14
from synthetic turf runoff.
Rather than relying on ineffective filtration, it would be far more responsible to critically
evaluate and reduce the sources of unnecessary plastic pollution—such as synthetic
turf—which contributes significantly to the problem. Cornell’s current plan falls short of
effectively mitigating environmental risks, given the evidence of limited success even with
more sophisticated technologies.
Pearce, Graeme. "PVDF Membranes and PFAS: What Impact of the EU’s REACH
Legislation?" The MBR Site, May 24, 2023. Updated January 20, 2024. Accessed October
10, 2024.
https://www.thembrsite.com/blog/pvdf-membranes-and-pfas-whats-the-difference.
This article by Dr. Graeme Pearce explores the growing regulatory challenges
surrounding PVDF (Polyvinylidene Fluoride) membranes in the context of the
European Union's REACH legislation, which aims to limit or ban the use of PFAS
chemicals. Pearce explains the dual role of PVDF in the membrane industry—while
PVDF is widely used for water filtration due to its chemical resistance and durability, its
classification as a PFAS brings it under scrutiny due to concerns about contamination
and environmental impacts. The article offers a detailed comparison between the
approaches of the EU and the U.S. in regulating PFAS, with the EU favoring a
precautionary approach.
Silva, Ana L.P., Joana C. Prata, Armando C. Duarte, Amadeu M.V.M. Soares, Damià
Barceló, Teresa Rocha-Santos. “Microplastics in Landfill Leachates: The Need for
Reconnaissance Studies and Remediation Technologies.” Case Studies in Chemical and
Environmental Engineering. June 2021. https://doi.org/10.1016/j.cscee.2020.100072
This study highlights how microplastics and nanoplastics in landfill leachates contribute
to the increased leaching of plastic additives, such as plasticizers, and facilitate the
adsorption/desorption of hazardous chemicals and pathogens in water. The presence of
these plastics raises significant concerns about environmental and human health impacts.
Chemicals from plastics, including PFAS, BPA, cadmium, mercury, and lead, are often
water-soluble and persistent, making them difficult to remove from water systems with
mechanical filtration. As plastics degrade, their surface area increases, accelerating the
release of harmful substances. The authors stress the importance of developing
remediation technologies to address these threats.
Simpson, Thomas J., and Robert A. Francis. “Artificial Lawns Exhibit Increased Runoff and
Decreased Water Retention Compared to Living Lawns Following Controlled Rainfall
Experiments.” Urban Forestry & Urban Greening 63 (2021): 127232.
https://doi.org/10.1016/j.ufug.2021.127232.
This study examines the hydrological impacts of artificial (synthetic polymer) grass
compared to living grass using controlled rainfall experiments. It finds that artificial
grass, especially with longer pile heights, produces greater runoff and sheds plastic
15
thatch and fibers, posing environmental concerns; living grass demonstrates superior
water retention and drainage control.
Zhang, Xiaoran, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, and Ziyang Zhang.
Distribution and Health Risk Assessment of Some Trace Elements in Runoff from
Different Types of Athletic Fields." International Journal of Environmental Research and
Public Health, first published March 2, 2021. https://doi.org/10.1155/2021/5587057.
This study evaluates the distribution of seven trace elements (Zinc (Zn), Lead (Pb),
Copper (Cu), Manganese (Mn), Cadmium (Cd), Arsenic (As), Chromium (Cr)) in runoff
from five types of athletic fields, including artificial turf. The results reveal that artificial
turf generates the highest concentrations of these pollutants compared to other
surfaces like tennis courts and basketball courts, particularly in initial rainfall events.
Notably, pollutants in artificial turf runoff exhibit the least correlation, indicating diverse
and unconnected sources such as surface materials, infill, coatings, and external
atmospheric deposition. This complexity underscores the unpredictability of synthetic
turf's chemical runoff and highlights its heightened pollution risk. Additionally, many
of these metals and metalloids are water-soluble and exist in dissolved ionic forms, which
cannot be captured by Cornell's proposed mechanical filtration system with a 212-micron
pore size. While Cornell claims its infills are “organic” and “PFAS-free,” broader
research shows that such toxins can leach from blades, backings, shock pads,
adhesives, coatings, and even atmospheric deposition. These findings emphasize the
need for comprehensive studies and monitoring. These findings emphasize that
pollutants in runoff cannot be attributed to a single source and highlight the need for
comprehensive monitoring and mitigation strategies tailored to the unique characteristics
of synthetic turf runoff.
More Omitted
Zhang, Xiaoran, Yupeng Gu, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, Ziyang
Zhang, Chaohong Tan, Yu Wang, and Haiyan Li. “Occurrence and Risk Assessment of
PAHs from Athletic Fields under Typical Rainfall Events.” Water Science & Technology
87, no. 9 (2023): 2159–2171. https://doi.org/10.2166/wst.2023.092.
This study examines the release of PAHs from various athletic field surfaces during
rainfall, finding significantly higher PAH concentrations in runoff from artificial turf
compared to other surfaces. While PAHs are often associated with crumb rubber infill,
research has shown that PAHs can also be present in turf blades and backings due to
manufacturing additives, plasticizers, recycled plastics and carbon black. This is critical
because Cornell’s claim of using plant-based infill for some outdoor turf does not address
the contamination risks posed by the synthetic turf itself.
From:
To:
Cc:
Subject:
Attachments:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Submission of ZWI's Legal Response and Supplementary Materials
EF2024_0816_Zero_Waste_Ithaca_v_Zero_Waste_Ithaca_MEMORANDUM_OF_LAW_I_48.pdf;Revised
paragraphs .docx;My notes about Response to Cornell’s _Memorandum_ in Opposition to ZWI Petition
on Synturf Projects-1.pdf;
3/18/2025 9:05:45 AM
WARNING** This email comes from an outside source. Please verify the from address, any URL links,
and/or attachments. Any questions please contact the IT department
Dear Members of the Town of Ithaca Planning Board,
I am submitting Zero Waste Ithaca’s legal response to Cornell University’s petition regarding the synthetic turf
project, along with an additional document—"Revised Paragraphs"—which provides expanded explanations of
key arguments from page 14 of 17. This document reflects my own interpretation as a legal layperson attempting
to understand Pace Environmental Litigation Clinic (PELC)'s legal argument. In essence, it is my personal
translation of the latter half of PELC's argument into more accessible language.
Given the strict word limits imposed on our legal filing, it appeared to me PELC had to condense several critical
points. As a result, I personally found it necessary to translate and expand the legal document to fully grasp its
implications. In doing so, I realized this could also be helpful for members of the Planning Board, as it is essential
to ensure that Cornell’s response is not left uncontested or assumed to be the definitive interpretation of the facts.
To that end, the attached "Revised Paragraphs" document expands upon page 14 of 17 of PELC's response
EF2024_..., attached) and clarifies several major areas where Cornell’s arguments are misleading, incomplete, or
scientifically inaccurate. Specifically, it addresses:
The inadequacy of Cornell’s claims regarding microplastic pollution, including their failure to cite
legitimate, peer-reviewed research.
The improper reliance on mitigation measures instead of conducting a full Environmental Impact
Statement (EIS), which is legally impermissible under SEQRA.
The omission and misrepresentation of scientific findings on PFAS, microplastics, and volatile organic
compounds (VOCs)—all of which pose significant environmental and public health risks.
The Planning Board should not accept Cornell’s response as an absolute truth without considering the broader
context and evidence. The attached materials demonstrate that a full EIS is legally required to assess the
environmental impact of synthetic turf.
Additionally, I am attaching my notes regarding Cornell's responses from the administrative records for the
court, which include their original submissions to the Town and City of Ithaca Planning Boards. Given the
misrepresentation of science in Cornell's submission, I felt compelled to conduct my own research and verify
their inaccuracies. It mentions conflicts of interest of Frank Rossi, about whom I have already submitted a public
comment.
We appreciate the Planning Board’s willingness to carefully review all perspectives to ensure a decision based on
a complete and accurate understanding of the environmental risks involved. Please feel free to reach out if
further clarification is needed.
I hope this further underscores the need for a GEIS for the entire Game Farm Road Project.
Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings,
which you are leaning to disregard as you move forward with a Negative Declaration.
Sincerely,
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
STATE OF NEW YORK
SUPREME COURT: COUNTY OF TOMPKINS
ZERO WASTE ITHACA,
Petitioner
v.
ITHACA CITY PLANNING &
DEVELOPMENT BOARD AND CORNELL
UNIVERSITY
Respondents
Index No.: EF2024-0816
Justice Mark G. Masler
REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT
OF VERIFIED AMENDED PETITION
Todd D. Ommen
Julianne Frey
Attorneys for Plaintiff
PACE ENVIRONMENTAL LITIGATION
CLINIC, INC.
78 North Broadway
White Plains, New York 10603
Phone: (914) 422-4343
Fax: (914) 422- 4433
CI2025-03769 Index # : EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
1 of 17
TABLE OF CONTENTS
PRELIMINARY STATEMENT ...........................................................................................1
ARGUMENT .........................................................................................................................2
1. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED
THE BECAUSE THE ZWI MEMBERS HAVE STANDING TO BRING THIS
LAWSUIT ...............................................................................................................2
A. Petitioner Effectively Alleged Injuries Different from Those of The
General Public ................................................................................................2
B. Regardless of Whether or Not the Property is Private, There is Still an
Ability to Challenge the Planning Board’s SEQRA Decision .......................5
C. ZWI Has Always Had Standing to Bring This Petition .................................6
2. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE
PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK
REVIEW” AS REQUIRED BY STATUTE, AND THE NEGATIVE
DECLARATION IS ARBITRARY AND CAPRICIOUS. ......................................7
A. The Standard of Review Under SEQRA is A Hard Look Review ................7
1. PFAS ...............................................................................................8
2. Microplastic Shedding ....................................................................10
3. Air Emissions and VOCs ................................................................10
B. The Negative Declaration relies on the Respondent’s Future Actions
making it Conditional ....................................................................................11
CONCLUSION ......................................................................................................................12
CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT ....................12
CI2025-03769 Index #: EF2024-0816
FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025
2 of 17
ii
TABLE OF AUTHORITIES
Cases
Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating,
849 N.Y.S.2d 112 (3d Dep’t 2007) ................................................................................... 3
Cannon v. Murphy,
600 N.Y.S.2d 965 (2d Dep’t 1993) ................................................................................... 11
Elizabeth Street Garden, Inc v. City of New York,
42 N.Y.3d 992 (2024) ...................................................................................................... 2, 7
Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton,
613 N.Y.S.2d 257 (2d Dep’t 1994) .................................................................................. 11
Heritage Coal. v. City of Ithaca Planning and Dev. Bd.,
644 N.Y.S.2d 374 (3d Dep’t 1996) ................................................................................... 4, 5
Jackson v. New York State Urban Dev. Corp.,
67 N.Y.2d 400 (1986) ....................................................................................................... 7
Merton v. McNally,
90 N.Y.2d 742 (1995) ....................................................................................................... 11
New York City Coal. for the Preserv. of Gardens v. Giuliani,
666 N.Y.S.2d 918 (1st Dep’t 1998) .................................................................................. 3
Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency,
720 N.Y.S.2d 768 (Sup. Ct. Westchester Cnty. 2001)...................................................... 6
Saratoga Lake Prot. v. Dep’t of Public Works,
846 N.Y.S.2d 786 (3d Dep’t 2007) ................................................................................... 3
Save Pine Bush, Inc. v. Common Council of City of Albany,
13 N.Y.3d 297 (2009) ....................................................................................................... 1
Save the Pine Bush, Inc. v. Town of Guilderland,
168 N.Y.S.3d 561 (3d Dep’t 2022) ................................................................................... 6
Save Our Main St. Bldgs. v. Greene County Legis.,
740 N.Y.S.2d 715 (3d Dep’t 2002) ................................................................................... 4
Seneca Lake Guardian v. New York State Dep’t Env’t Conserv,
216 N.Y.S.3d 78 (3d Dep’t 2024) ..................................................................................... 6
Shapiro v. Torres,
60 N.Y.S.3d 366 (2d Dep’t 2017) ..................................................................................... 2
W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown,
861 N.Y.S.2d 864, 866 (3d Dep’t 2008) ........................................................................... 9, 11
Rules
N.Y. CPLR Rule 1025 (McKinney 2000) .............................................................................. 6
CI2025-03769 Index #: EF2024-0816
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Regulations
6 NYCRR § 617.7(b) .............................................................................................................. 7
N.Y. Env’t Conserv. Law §8-0101 ......................................................................................... 7
N.Y. Env’t Conserv. Law §8-0109 ......................................................................................... 7
N.Y. Env’t Conserv. Law §27-3313 (2) ................................................................................. 9
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PRELIMINARY STATEMENT
Petitioner Zero Waste Ithaca (“ZWI”) respectfully submits this Reply memorandum in
further support of its Amended Petition challenging Respondent Ithaca Planning and
Development Board’s (the “Planning Board”) arbitrary and capricious finding under the State
Environmental Quality Review Act (“SEQRA”) that Respondent Cornell University’s
collectively with the Planning Board, “Respondents”) use of artificial turf fields will have no
possible significant adverse environmental impact (the “Negative Declaration”). The Planning
Board’s failure to order an Environmental Impact Statement (“EIS”) violates SEQRA’s
fundamental purpose: investigating and mitigating environmental harm before it occurs. ZWI
brings this petition because its members—who regularly work, study, and engage on Cornell's
campus and community—will be directly harmed by the disregard for public health and
environmental responsibility.
Rather than focusing on defending the Negative Declaration on the merits, Respondents
initially allege that ZWI has no standing to bring this suit. Respondents first argue that ZWI’s
members suffer no particularized harm from the Negative Declaration, but this contention
ignores that, unlike the public at large, ZWI’s members rwork, study, and engage with Cornell’s
campus every day. ZWI has demonstrated that its members would suffer harm different from that
of the general public including the degradation and recreational, environmental and aesthetic
interests in nature and green space. Save Pine Bush, Inc. v. Common Council of City of Albany,
13 N.Y.3d 297, 304 (2009). Moreover, ZWI had the ability to bring suit as an unincorporated
association, but even if this were a defect, that defect has now been rendered moot by ZWI’s
incorporation.
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Similarly, Respondents’ assertion of a proper “hard look” review of the potential
environmental impacts and the finding of no significant adverse environmental impacts largely
ignores the extensive record in this matter. The fact that Respondents can point to a handful of
papers or studies that at least in part support their position does not establish that there will be no
possibility of any adverse environmental impact, as required by SEQRA. Elizabeth Street
Garden, Inc v. City of New York, 42 N.Y.3d 992, 995 (2024). Absent such a showing, where, as
here, there is ample research and analysis showing potential impacts, the only legal path was for
Respodents to complete an EIS. Citing only a handful of studies—while disregarding a
substantial body of research demonstrating potential harm—does not satisfy SEQRA’s “hard
look” requirement.
ARGUMENT
I. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED
BECAUSE THE ZWI MEMBERS CAN ESTABLISH STANDING TO BRING
THIS LAWSUIT.
Respondents assert that Petitioner lacks standing because its members do not suffer an
injury different from the general public, that the members cannot access the project site, and
ZWI’s unincorporated status at the time the Petition was filed. Each of these contentions fails
after review of the record and circumstances of this dispute, as well as developments since the
filing of the Petition.
A. Petitioner Sufficiently Established Injuries Different from Those of the General
Public.
To establish standing under SEQRA, a petitioner must demonstrate an environmental
injury different from the general public and that the alleged injury falls within the scope of
interests being protected by SEQRA. Shapiro v. Torres, 60 N.Y.S.3d 366, 368 (2d Dep’t 2017).
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The offices of ZWI member Emily Jernigan, a Cornell University full-time staff member and
Amina Mohamed, a Ph.D. candidate in Ecology and Evolutionary Biology, are located very near
the proposed project site. Respondent asserts that their offices, 560 feet and 265 feet away from
the project site, respectively, are too far away from the site to establish standing. (NYSCEF Doc.
No. 43, pp 11.). Referencing New York City Coal. for the Preserv. of Gardens v. Giuliani,
Respondents compare these facts, two community members of a private institution as similar to
trespassers who had established a community garden on a vacant lot. 666 N.Y.S.2d 918, 918-19
1st Dep’t 1998) aff’g 670 N.Y.S.2d 657, 659 (Court dismissed a SEQRA petition on standing
grounds as petitioners did not have any legal right to the garden). Ms. Jernigan and Mohamed did
not use the field as it is restricted to athletics, and ZWI does not contend that the project site is
available to them. But, notwithstanding that the field may be off limits to non-athletes, proximity
can still establish standing. As Cornell community members, ZWI members must be in the
vicinity for work and study and have an interest in and enjoy the natural environment. That
environmental is what is threated by the PFAS, microplastics and other toxins that would be
released by the proposed field, as set forth in the Amended Petition. Indeed, proximity
established by ZWI’s affiants is well within the range of that found sufficient for SEQRA
standing. The Third Department has previously held that proximity within 1,000 feet of a
development site can be sufficient to establish. See, Saratoga Lake Prot. v. Dep’t of Public
Works, 846 N.Y.S.2d 786, 791 (3d Dep’t 2007) (petitioners demonstrated standing from 1,000
feet of development); Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849
N.Y.S.2d 112, 115 (3d Dep’t 2007) (petitioner alleged an injury differentiated from that of the
general public because her residence was 941 feet away from the proposed project and identified
an environmental concern arising from that proximity). Ms. Jernigan and Mohamed’s offices are
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located much closer, within 560 and 265 feet of the project site, well within a distance sufficient
for standing (NYSCEF Doc. No. 43, memorandum of law in support denying petition at 11).
Respondents further argue that even if their offices were not too far removed, the campus
has ample green spaces for the Petitioners to enjoy and interact with nature. (NYSCEF Doc. No.
43 at 16-17). But this argument entirely misses the point of SEQRA, which is to protect the site
at issue. Ms. Mohamed said she often takes breaks in the area of the field. (NYSCEF Doc. No.
11, affirmation of Amina Mohamed at 2). The existence of other green spaces is simply
irrelevant. First, those neighboring green spaces are exactly what would be impacted by the
toxins emanating from the field, as multiple studies submitted to Respondents demonstrate. In
any event, SEQRA does not permit the degradation of one green space simply because other
green spaces may exist nearby. Ms. Mohamed does not allege to take breaks elsewhere; she takes
breaks around the project site. (Id.) The area she frequents, close to her office, the subject of this
petition – not other green spaces.
Respondents correctly state that proximity alone is not always enough to confer standing.
Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715, 717-18 (3d Dep’t 2002).
However, the matter here is substantially different from Save Our Main St. Bldgs., where the
petitioners did not allege any unique environmental injuries. Save Our Main St. Bldgs., 293
A.D.2d at 909 (petitioners alleged increased traffic concerns, one concerned about more traffic
for their store on the main street, noise complaints, an aesthetic injury despite the project not
being visible as it was on the same side of the street as petitioner’s store, and a petitioner who
was concerned about educational walks through a public main street.) Respondents’ reliance on
Heritage Coal. v. City of Ithaca Planning and Dev. Bd., to demonstrate as another example of
how the appreciation of a building, Cornell’s Sage Hall, was not enough of an injury, is
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misplaced. 644 N.Y.S.2d 374, 376-377 (3d Dep’t 1996) (dismissal of a SEQRA petition based
on standing; three educators failed to show how their injury was different from that of the
general public.) Heritage Coal. is distinguishable from the present matter because of the goals of
SEQRA; “...the diminution of [their] appreciation of Sage Hall and [their] use of it as a teaching
tool, is not, without more, within the zone of interest sought to be promoted or protected by
either SEQRA…” Id. at 376. In contrast, there can be no question that the environmental injuries
alleged here – environmental contamination from PFAS, micro plastics and other toxins – are
within the zone of interests of SEQRA.
ZWI members demonstrate unique environmental harms congruent with the SEQRA’s
aims and further allege a much closer connection to Cornell’s campus than the public at large.
See, N.Y. Envtl. Conserv. Law §8-101. Ms. Jernigan and Mohamed, by virtue of their proximity,
interests in the natural state of the campus, members of the faculty and staff, and Ms.
Mohamed’s breaks in the areas, establish harm greater than that of the general public.
B. Regardless of Whether the Property is Private, Petitioner Can Still Challenge
The Planning Board’s SEQRA Decision.
Respondents’ next argument focuses on the project site functioning as an athletics field
that is only accessible to authorized students; therefore, Respondents argue, ZWI members could
not have standing for a field they cannot enter the field. NYSCEF Doc. No. 43, 16-17. Case law
does not indicate that Petitioners must have access to the site to sustain an injury from a site’s
development. It is not and cannot be the law that development on a privately owned site is
immune from SEQRA challenges. Indeed, as discussed below, development will often naturally
occur on private property, and courts have found proper standing for environmental groups
nevertheless.
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The Petitioner’s standing should be considered within the entire scope of the facts. The
fact that the field may be, in a sense, “private” does not mean that those in proximity cannot have
standing. If it were otherwise, nobody would ever have standing to challenge development on
private property, which would eviscerate the purpose of SEQRA. To the contrary, the mere fact
that a standing witness does not have legal access to a property does not defeat standing. Indeed,
recently the Third Department held just that. In Save the Pine Bush, Inc. v. Town of Guilderland,
168 N.Y.S.3d 561, 566 (3d Dep’t 2022), the court held that an environmental group had standing
to challenge a development on private property due to the group’s interests in the surrounding
environment. See also, Seneca Lake Guardian v. New York State Dep’t of Env’t Conserv., 216
N.Y.S.3d 78, 81 (3d Dep’t 2014) (where the dumping of leachate into a water body not owned
by the plaintiff, found successful standing).
C. ZWI Has Always Had the Legal Ability to Bring This Petition, and Now Has
Been Incorporated.
Finally, Respondents’ argument that ZWI lack the capacity to sue was incorrect and, in
any event, is now moot, as ZWI is no longer an unincorporated entity. New York does allow
unincorporated organizations to bring legal actions, pursuant to the CPLR § 1025, which
provides that “[an action] may be brought by or against the president or treasurer of an
unincorporated association on behalf of the association in accordance with the provisions of the
general associations law.” While Ms. Koizumi, the founder of ZWI, may not be explicitly listed
as the organization's “president,” she functions and operates as such, performing the “equivalent
functions and responsibilities” of a small grassroots organization by advocating for change and
informing the public of potential risks. Pelham Council of Governing Bds. v. City of Mount
Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768, 770 (Sup. Ct. Westchester Cnty. 2001) (provides
that an unincorporated organization may proceed in a lawsuit if they function like a treasurer or
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president of an organization); see, NYSCEF Doc. No. 18 at pp 5 (demonstrating Ms. Koizumi’s
advocacy.) Additionally, the Respondent’s arguments about undertakings are entirely irrelevant,
as there has not been a preliminary injunction at this point and the issue of an undertaking is not
before the Court. NYSCEF Doc. No. 43 at 20.
In all events, the argument is now moot. As of January 27, 2025, ZWI is recognized by
New York State as a not-for-profit corporation. (See Affirmation of Yayoi Kozumi, submitted
herewith.)
II. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE
PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK”
AS REQUIRED BY STATUTE.
A. The Standard of Review Under SEQRA is A Hard Look Review.
ZWI will suffer tangible environmental harms from the planning board’s negative
declaration that the project will not have any potential adverse environmental impacts. (6
NYCRR § 617.7(b) (emphasis added)). SEQRA aims to “...encourage productive and enjoyable
harmony between man and his environment; to promote efforts which will prevent or eliminate
environmental damage and enhance human and community resources…” N.Y. Envtl. Conserv.
Law § 8-0101. To accomplish these goals, applicants must complete an environmental
assessment form (EAF) to determine when a longer, more in-depth environmental assessment, an
EIS, is necessary. Id. at § 8-0109. The determination of whether to complete an EIS must be
based on the agency (here the Planning Board) taking a “hard look” at all potential impacts. A
hard look” review is when “the lead agency [identifies] the relevant areas of environmental
concern, [takes] a ‘hard look’ and [makes] a reasoned elaboration’ on the basis for its decision.”
Elizabeth Street Garden, 42 N.Y.3d at 994 (2024) (omitting internal quotations); see, Jackson v.
New York State Urban Dev. Corp., 67 N.Y.2d 400, 417 (1986.) If, after taking that “hard look,”
there are any potential adverse impacts, an EIS is the only permissible next step under SEQRA.
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Put another way, where the material before the reviewing agency indicates that there is
any potential for a significant impact, the agency cannot rationally determine that the project will
not have a significant adverse impact on the environment. Elizabeth Street Garden, 42 N.Y.3d at
994. Respondents assert that the “multiple hours” spent at planning board meetings, reviewing
documents, and asking some questions was enough to counter the numerous contradicting
information and studies and glaring biases from fact gatherers the planning board relied on.
NYSCEF Doc. No. 43 at 24-25, 21). But the amount of time is not the question here; rather, the
question for this Court is whether that record revealed any potential impacts. The quantity of
time spent on an issue is not an indication that the Planning Board had a substantive review of
possible adverse environmental impacts. The mere fact there were 70 pages of citations to
contradictory studies presented to the Planning Board should have triggered an EIS as it indicates
at a minimum – an open question as to environmental impacts. NYSCEF Doc. No. 18 at pp 5
One organization’s, ZWI’s, submissions to the Planning Board for consideration.)
1. PFAS
Respondents have asserted time and time again that the science proving that artificial turf
fields is sound, going so far as saying that “[o]ver 100 scientific, peer reviewed, published
studies have been performed worldwide evaluating the potential health risks with turf fields that
use crumb rubber. We are not aware of any peer reviewed scientific studies that draw an
association between adverse health effects and use of crumb rubber.” NYSCEF Dos. No. 43 at 4.
It is again repeated that the PFAS concerns are not serious. Id. at 20 (Respondent states that they
have “rebutted” the claims). The question of health impacts is certainly relevant, but an EIS is
triggered under SEQRA by any significant adverse environmental impact, not just human health
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impacts. Petitioner was not required to prove medical causation to trigger an EIS. Potential
environmental impacts were obvious from the submissions to the Planning Board.
The bibliography provided to the Planning Board has several relevant studies affirming
synthetic turf is a concern. See generally, Bibliography NYSCEF Doc. No. 20. Similarly, though
the Respondents have stated that over 100 scientific and peer reviewed studies claim that there
are not adverse health effects linked to the use of crumb rubber, Respondents only cite to six. R.
0641-42. While Respondent’s insist that their own submitted documentation proved more
compelling to the Planning Board, that PFAS would not be a significant concern, Respondent’s
seemed to contradict their statement earlier in their memo that PFAS contamination is pervasive
already. NYSCEF Doc. No. 43 at 20, 4 (respondents allege their own material is persuasive
enough to the planning board that PFAS concerns are unimportant but suggest in their statement
of the facts their summary suggests that because PFAS are already pervasive in the environment
the amount from synthetic turf won’t be significant). Arguing that contamination is already
present should not and does not establish no possible environmental impacts.
Respondents also assert that because they modified their project to comply with a new
New York state ban on carpet containing PFAS, including synthetic turf, going into effect in
2026, the Planning Board was entitled to defer to Cornell’s compliance with applicable law when
issuing a negative declaration. N.Y. Env’t Conserv. Law §27-3313 (2). However, the ban going
into effect is further evidence that the Planning Board’s negative declaration decision was
arbitrary and capricious; environmental risks are associated, which is why there is a ban going
into effect in the near future. Id. There is a recognized environmental threat substantial enough to
warrant a statewide ban, this should not be ignored under SEQRA. Likewise, the case law
Respondents rely on to ameliorate concerns hinges on having already completed a
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comprehensive EIS. W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of
Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008). This is all Petitioner here seeks:
completion of an EIS to examine these open issues.
2. Microplastic Shedding
Respondents assert that they have “submitted extensive documentation from scientific
studies” about microplastics. NYSCEF Doc. No. 43. at p. 21. However, this is misleading as the
record indicates that one letter, from the Respondent’s employee Dr. Frank Rossi, addressed
microplastics. R. 0622-23. The content of Dr. Rossi’s letter focused primarily on the necessity of
a synthetic turf field and the alleged adequacy of a microplastic filter. Id. The letter only
referenced one scientific study, and it did not name it. Id. This one reference without citing a
relevant study is in stark contrast from the alleged extensive documentation. ZWI submitted
several studies from credible environmental journals and other sources explaining the risks of
microplastics entering the environment. NYSCEF Doc. No. 20 at 33. ZWI submitted information
from at least two scientific studies, Chand et al., 2024 and Park et al., 2022, demonstrating that
the proposed stormwater filter, added to mitigate plastic pollution in runoff, would not be
sufficient as the plastic degrades and becomes smaller than the 212-micron pore size of the filter,
leading to plastic pollution and contamination in waterways. R. 1425.
In this same vein, the EPA in 2024 documented that the majority of people who had used
synthetic turf fields would have find the fill on their person, in their cars and in their homes after
the fact (R.1700) demonstrating the difficulty and confirming that synthetic turf users routinely
carry microplastics on their skin, shoes, and clothing, dispersing them into homes, cars, and
water systems.
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3. Air Emissions and VOCs
Despite the Respondent’s contentions, the record lacks scientific studies showing a
consensus that emissions and VOCs from synthetic turf fields have no health impacts. Initially,
as noted above, Petitioner was not required to show health impacts – rather, environmental
impacts are the question. In any event, Respondents cite to a 2018 Guidance Document from the
New York State Department of Health quoting that the exposures to VOCs, SVOCs and airborne
particulate matter was insignificant and not unlike the exposure a person would have on a natural
turf field. NYSCEF Doc. No. 43 at 21-22. Respondents failed to include the part of the quote that
says when the synthetic field is not exposed to open air, when “collected from an indoor
synthetic turf field [air samples] had higher concentrations [of VOCs, SVOCs and airborne
particulate matter] than the outside fields.” R. 3152. The earlier 2018 study in complete context
corroborates the recent findings from a 2023, among many others, that microplastic inhalation is
a confined indoor space is an elevated risk due to microplastic’s small size and density
compounded with their ability to stay in the space due to a lack of air circulation. R.1426. ZWI
raised several other concerns about air borne microplastics and environmentally persistent free
radicals from reputable academic sources, the Center for International Environmental Law and
Huang et al., 2022, that went unaddressed. Id.
B. The Negative Declaration relies on the Respondent’s Future Actions making it
Conditional
The insufficient detail provided in the negative declaration reasoning, despite the variety
of potential environmental impacts, means the Planning Board's issuance of the negative
declaration violated SEQRA. See, Farrington Close Condominium Bd. of Managers v. Incorp.
Vill. of Southampton, 613 N.Y.S.2d 257, 259 (2d Dept 1994); Cannon v. Murphy, 600 N.Y.S.2d
965, 968 (2d Dept 1993).
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The Planning Board's reliance on future actions and mitigation measures as justification
for foregoing an EIS is impermissible. The cases the Respondents point to, W. Beekmantown
Neigh. Ass’n Inc and Merton v. McNally, are fundamentally different in the extent of their
mitigation. W. Beekmantown Neigh. Ass’n Inc, 861 N.Y.S.2d at 866 (mitigation after an EIS had
already been done did not require another EIS); Merton v. McNally, 90 N.Y.2d 742, 755 (1995)
mitigation entailed adding an additional 2 feet of buffer space).
Ultimately the planning board’s decision was not merely arbitrary and capricious given
the record but also patently wrong about the facts. It is established that it is not for this Court to
determine the whether the planning board’s reasoning for a negative declaration is adequate, it is
within the scope to determine if it complied with SEQRA requirements in finding no potential
significant impact. Here, due to its failure to adequately assess key issues in the record, the
Planning Board plainly did not comply.
CONCLUSION
For the reasons outlined above, Petitioners respectfully request that this court maintain
allow our petition to go forward.
Dated: February 13, 2025
White Plains, NY
Respectfully submitted,
Todd D. Ommen
Pace Environmental Litigation Clinic, Inc.
78 North Broadway
White Plains, NY 10603
914) 422-4343
tommen@law.pace.edu
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CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT
The undersigned attorney hereby certifies:
This document complies with the word count limitations pursuant to Rule 202.8-b (c) of
the Uniform Civil Rules for the Supreme Court and the County Court as amended by the
Administrative Order 270-20, effective February 1, 2021. According to the word processing
system used in this office, this document, exclusive of the sections excluded by Rule 202.8-b (b),
contains 3,595 words.
Dated: February 13, 2025
Todd D. Ommen
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Summary of Objections to Cornell’s 30-Page Legal
Memorandum
1. Misrepresentation of Scientific Evidence and Cherry-Picked Studies
Cornell claims that “over 100 peer-reviewed studies” support synthetic turf safety (page 4) but
fails to list them.
Instead, their April 2024 submission “Additional Materials” contains only 12 references
R1571-R1572), three of which have clear industry conflicts of interest:
Peterson et al. – Connected to the recycled rubber industry.
Schneider et al. (2020) – Funded by synthetic turf and tire recycling companies.
Blair – Advised by Laura Green, a discredited industry consultant known for
downplaying PFAS risks.
Two of the 12 references come from consulting firms (Tetra Tech and TRC), which reference
each other’s reports—creating an industry echo chamber. This was brought up repeatedly in
public comments. Notably, Tetra Tech’s report was rejected by the Town of Oak Bluffs on
Martha’s Vineyard in MA. The town proceeded to ban artificial turf despite Tetra Tech’s report.
This fact presented in multiple public comments multiple times is conveniently omitted from
Cornell’s presentation.
Of the three EPA sources cited in the 12 references on which Cornell’s legal response rests on,
only one—the 2019 report, Tire Crumb Rubber Characterization—is directly related to
synthetic turf issues involving tire-derived crumb rubber (TDCR). This report, commonly referred
to as FRAP 1 (Federal Research Action Plan, Part 1 - Final Report Part 1, Tire Crumb Rubber
Characterization), has been widely mischaracterized by the synthetic turf industry. In their
response (R1564-1567), Cornell relies on FRAP 1 to justify synthetic turf installations, yet their
interpretation is misleading. The EPA explicitly stated that FRAP 1 was not a risk assessment
and that the study was only intended to characterize the presence of chemicals in tire crumb
rubber, not determine the risks of exposure or health effects. However, Cornell presents the
findings as though they confirm the safety of synthetic turf, when in reality, the report did not
make any determinations about health risks. This deliberate misrepresentation mirrors a
pattern of selective and misleading use of evidence throughout their response.
The FRAP1 also confirms that recycled tire crumb rubber contains metals, PAHs,
phthalates, and other chemicals. Some of these are known to be carcinogenic or have other
toxic effects. The report also shows that volatile organic compounds (VOCs) and semi-volatile
organic compounds (SVOCs) are emitted, particularly at higher temperatures
60°C/140°F)—a temperature synthetic turf commonly reaches in summer. By downplaying
these emissions or ignoring temperature-dependent off-gassing, they are omitting critical
data that affects health risk. FRAP 1 does not quantify real-world human exposure, meaning
Cornell cannot legitimately conclude that synthetic turf poses "no risk" based on this study alone.
Cornell also fails to address bioaccessibility and exposure uncertainties addressed in FRAP1. The
EPA measured how metals and chemicals leach into simulated gastric fluid, saliva, and
sweat, finding that some metals are bioaccessible.
FRAP 1 also acknowledges significant data gaps in its report, particularly regarding long-term
exposure, biomonitoring, and cumulative effects. Cornell cherry-picks evidence while ignoring
the study’s stated limitations by presenting FRAP1 as definitive proof of safety.
In addition to FRAP 1, Cornell lists two other EPA sources that have little or no direct relevance
to synthetic turf or TDCR. The first, “Regional Screening Levels for Chemical
Contaminants at Superfund Sites - Generic Tables”, is an EPA database of chemical exposure
guidelines used primarily for hazardous waste sites under the Superfund program. This document
is completely unrelated to synthetic turf and has no relevance to tire crumb rubber exposure
scenarios on athletic fields. This report is referenced on R1564. The document states that when
New York State Soil Cleanup Objectives (SCOs) were unavailable, they defaulted to the EPA
Regional Screening Levels (RSLs) as a substitute. However, the EPA’s RSLs are not direct
regulatory limits—they are risk-based screening tools used to determine if further evaluation is
needed. This is not equivalent to New York’s SCOs, which are legally enforceable cleanup
standards. The EPA RSL page they reference (linked here) explicitly states that RSLs do not
determine cleanup levels; they are preliminary screening values intended to flag potential
areas of concern. Cornell's conclusion that synthetic turf is "safe" based on EPA RSLs is not
scientifically valid. Instead of providing a site-specific risk assessment using New York’s actual
regulatory cleanup standards, they are misapplying an EPA tool meant for screening, not final
safety determinations. This creates a false impression of safety and ignores the precautionary
principle that should be applied when dealing with long-term contamination risks.
The second source, “Learn About Heat Islands”, is a general EPA webpage discussing urban
heat islands, including buildings, pavement, and land use, but not synthetic turf specifically.
While synthetic turf contributes significantly to urban heat island effects, this source does not
analyze synthetic turf's heat retention properties in any meaningful way. This EPA source is
referenced on R1570 where Cornell claims the EPA states heat islands “build throughout the day
and become more pronounced at night.” Ths misrepresents the source. The EPA page does
acknowledge that urban materials release stored heat after sunset, contributing to higher nighttime
temperatures relative to rural areas, but it does not state that nighttime temperatures exceed
daytime temperatures or that heat islands intensify at night. This is a misleading paraphrase that
overstates the EPA’s wording to fit Cornell’s narrative. Its inclusion suggests an attempt to appear
comprehensive while failing to cite any substantive research on the specific heat hazards of
artificial turf fields.
Most notably, despite relying so heavily on FRAP 1, Cornell completely ignored FRAP 2 (2024)
in its April 2024 submission, even though FRAP 2 was published that same month. The
second July submission does mention FRAP 2 but only to misrepresent its findings. On page
4 of their July 2024 submission of Additional Materials (R0634), Cornell falsely claims that a
study published in 2024 by USEPA that used biomonitoring of athletes demonstrated that
no exposures occurred to the chemicals in synthetic turf and crumb rubber.” This statement
is demonstrably false. FRAP 2 explicitly found that players are exposed to hazardous
chemicals through inhalation, dermal contact, and ingestion, particularly in indoor settings
where concentrations were highest. By ignoring FRAP 2 entirely in their April submission and
then distorting its findings in their July submission, Cornell has engaged in a clear attempt to
downplay exposure risks while selectively citing irrelevant EPA sources.
This pattern of misrepresentation is further evident in how Cornell frames the issue of exposure.
Throughout their response, they repeatedly claim that while chemicals are present in synthetic
turf, the risk of exposure is negligible and not a concern. This is a deliberate
mischaracterization of the scientific process and regulatory approach to chemical exposure.
The presence of hazardous substances alone is not what determines risk—the question is whether
and how people are exposed, and whether cumulative, chronic exposure poses long-term
health effects. FRAP 2 was specifically designed to answer these questions, yet Cornell
systematically avoids engaging with its findings because doing so would undermine their
central argument.
In their April submission, Cornell spends four full pages misrepresenting FRAP 1
R1564-1567), treating it as though it supports their claim that synthetic turf is safe, when in
reality, FRAP 1 did not assess risk at all. The EPA 2019 report explicitly states that it is not a
risk assessment. Instead, it is a characterization study that identifies the chemical composition
of tire crumb rubber but does not evaluate the health risks associated with exposure.
Then, in their July submission, they strategically acknowledge FRAP 2 only to distort its
conclusions (R0634), rather than engaging with the actual findings of increased exposure risks.
This demonstrates an intentional and calculated effort to manipulate the scientific record to
serve a predetermined conclusion in favor of synthetic turf. If Cornell were genuinely
committed to scientific integrity, they would have prominently addressed FRAP 2’s findings in
full, rather than omitting it in April and distorting it in July.
By selectively citing an outdated EPA report while ignoring and later misrepresenting the
agency’s most recent and relevant research, Cornell’s response lacks credibility. Their use of
unrelated EPA sources further underscores an effort to obscure rather than clarify the scientific
and regulatory understanding of synthetic turf risks. This is not a rigorous or honest engagement
with the evidence—it is a strategic misrepresentation designed to manufacture doubt and
avoid accountability for the well-documented exposure risks posed by synthetic turf.
Of the 12 references on R1571-1572, Cornell also misrepresents Pavilonis et al. study on
R1564. While Pavilonis et al. (2014) found that most metals and SVOCs had low
bioaccessibility, they explicitly stated that lead was an exception, with some fields containing
high levels. Their risk assessment showed that children could have elevated blood lead levels
depending on exposure, which contradicts Cornell’s blanket claim of safety. The authors
recommended that turf should be screened for lead before installation, which implies a concern
that Cornell completely ignores. Further, the study analyzed only seven fields—hardly a
representative sample of all artificial turf. The study used EPA’s risk assessment methods, but as
we've seen with their misuse of EPA RSLs, regulatory thresholds are not always
health-protective—especially for chronic, low-dose exposures. The Pavilonis study itself
acknowledges data gaps, but Cornell’s summary presents it as definitive proof of safety, which is
scientifically dishonest.
Cornell also misrepresents the findings of CY Jim’s study on the heat island effect listed as
one of the 12 references on R1570. A recent public comment addresses that. Please see the tab
CY Jim for details. This leaves only Pronk et al (2020) out of 12 as a valid study - even that
study is also misrepresented, as it also acknowledges data gaps and explicitly state that more
research is needed on long-term exposure, particularly for inhalation and dermal absorption of
chemicals released from crumb rubber, and that athletes and children have higher exposure due
to direct skin contact and inhalation of volatile compounds, which could pose risks not fully
captured by existing guidelines. It also notes that athletes and children have higher exposure due
to direct skin contact and inhalation of volatile compounds, which could pose risks not fully
captured by existing guidelines. In conclusion, Cornell cherry picked the entire 12 studies.
Compare this to Zero Waste Ithaca’s bibliography containing several dozens of valid,
reputable, independent peer-reviewed studies, legitimate reports, and testimonies from
independent experts.
Cornell’s July 2024 submission of “Additional Materials” cherry-picks from our originally
submitted 70-page bibliography and misrepresents studies for their purposes —public comments
for the newly proposed field address this.
On R0637-R0638, Cornell’s reliance on Magnusson & Macsik (2017) to justify
synthetic turf’s emissions and human health safety is misleading and incomplete. They
cherry-pick this study while ignoring multiple studies we submitted on synthetic turf
emissions, including research on methane emissions from degrading turf by Dr. Sarah
Jean-Royer (2018).
Cornell’s emissions comparison ignores these critical factors and utterly fails to
acknowledge that natural grass fields sequester carbon, whereas synthetic turf
continuously emits greenhouse gases. Synthetic turf’s emissions must also be evaluated
across its entire lifecycle, including raw material extraction, manufacturing,
transportation, installation, use, and disposal.
Cornell also misrepresents the study’s findings on human health risks, claiming that the
introduction includes a table summarizing 26 studies, all demonstrating minimal risk.
This is false. While the study contains a table listing various studies, it does not conclude
that all 26 studies find minimal risk. Instead, the table categorizes different environmental
and health considerations, and some of these studies acknowledge concerns about
chemical exposure, microplastic release, and environmental degradation.
Magnusson & Macsik (2017) primarily focus on energy use and emissions, not
toxicology or microplastic pollution, making it an inappropriate reference for health risk
assessments. Cornell distorts the intent of this table by falsely presenting it as definitive
proof of synthetic turf safety. A scientifically sound approach would require a
comprehensive review of emissions, microplastic pollution, PFAS contamination, and
lifecycle environmental costs, rather than relying on a single, cherry-picked study.
On R0638, Cornell’s response misrepresents the findings of Tarafdar et al. (2019).
Cornell’s response to Tarafdar et al. (2019) is a textbook example of selective
interpretation designed to downplay the risks of synthetic rubber surfaces. Their claim
that PAHs detected in the study originate primarily from external sources like vehicular
emissions and fossil fuel combustion does not negate the fact that poured-in-place (PIP)
rubberized playgrounds were found to pose a 10-times higher cancer risk than uncovered
soil playgrounds.
Cornell conveniently omits a critical point: the rubberized surfaces themselves act as
accumulators of PAHs, trapping these toxic compounds and increasing children’s
exposure risk. Even if the study did not explicitly identify tire-derived crumb rubber
TDCR) as the main PAH source, that does not mean TDCR is free from PAHs. In reality,
TDCR has been well-documented to contain and release PAHs as it breaks down—a fact
confirmed by experts, even by the 2019 EPA report they reference to.
By narrowly focusing on settled dust, Cornell ignores the larger body of evidence
showing that PAHs are intrinsic to synthetic rubber materials. Instead of addressing the
clear finding that children face significantly higher PAH exposure in rubberized
playgrounds, they attempt to shift blame to external pollution, sidestepping the critical
health implications of these toxic surfaces.
It is also curious why Cornell focuses on this particular study on TDCR which is not
On R0638-0639, Cornell’s response downplays the Huang et al.’s (2023) findings
by suggesting that U.S. tires are different from Chinese tires—a baseless claim
with no supporting evidence. Tires worldwide contain similar toxic compounds,
and if Cornell truly believed there was a difference, they should present evidence.
They also claim that EPFRs (environmentally persistent free radicals) are "not
typically used as a measure of health effects," which is misleading. EPFRs are
widely studied in air pollution research because they produce reactive oxygen
species (ROS), which drive oxidative stress, inflammation, and cellular
damage—a key mechanism in many diseases, including cancer and respiratory
conditions. EPFRs are an established risk factor in toxicology.
While Cornell acknowledges that crumb rubber particles are airborne, increase
EPFRs in saliva, and inhibit enzyme function, they try to neutralize the findings
by saying these effects weren’t statistically significant at measured
levels—ignoring cumulative exposure, long-term impacts, and individual
variability.
On R0639, Cornell’s dismissal of Peaslee’s findings by focusing on a four-slide
presentation rather than engaging with the broader body of research on PFAS in
artificial turf is a clear case of cherry-picking. While they attempt to discredit his
calculations by questioning sample preparation and methodology, they
conveniently ignore peer-reviewed studies that provide extensive evidence of
PFAS contamination in synthetic turf, including Peaslee and Mello (2022),
Massey et al. (2020), Lauria et al. (2022), Murphy (2022), Negev et al. (2022),
and Siegel (2024) and more, all available in our bibliography. Moreover, Dr.
Peaslee supervised Whitehead’s 2023 PhD dissertation, which systematically
analyzed 27 turf blade samples and confirmed the presence of PFAS in all of
them, including fluorinated polymer processing aids, yet Cornell makes no
mention of these rigorous research. Their selective engagement with a single
presentation, rather than the full range of published studies demonstrating the
dangers of PFAS in turf, exposes their attempt to downplay the issue rather than
engage in an honest scientific discussion.
On R0639, Cornell also outrightly seems to tell untruth when they discuss Gould 2022
study that survey’s past literature on the injuries from playing on synthetic turf surfaces.
Cornell says, “This article has been responded to previously within these materials.”
However I find no reference anywhere in the document other than this. Cornell provides
no meaningful engagement with Gould et al.’s findings on higher lower-extremity injury
rates on synthetic turf.
On R0640, Cornell’s reading of the study by De Haan et al. (2023) attempts to
downplay the relevance of the findings to their proposed artificial turf field by
emphasizing differences in construction and drainage systems between European and
U.S. turf fields. While U.S. fields often include sand layers, there is no evidence that this
significantly prevents the release of microplastics into stormwater (See the list of videos
showing turf deterioration in the US in the separate tab), nor does it address fiber loss
through wear, wind dispersion, and maintenance activities. The study found that artificial
turf fibers make up over 15% of mesoplastics and macroplastics in aquatic environments,
with significant quantities detected in both river and ocean waters. This confirms that
artificial turf is a major contributor to plastic microplastic pollution, regardless of
regional construction differences.
Bethesda, MD. 2019.
Cornell’s dismissal of the University of California, Santa Barbara decision to opt for
natural grass based in a large part due to this study as being solely due to proximity to the
ocean ignores the broader implications of the study: artificial turf fibers are a persistent
pollutant that enter ecosystems through multiple pathways, including air, soil, and
indirect water transport. Given that Cornell’s campus is near Cayuga Lake and its
tributaries, the potential for fiber migration into drinking water supplies is undeniable.
On R0640, Cornell focuses on the recommendation to incorporate additional trees,
shrubs, and natural grasses when using artificial grass by Sanchez-Sotomayor et al.
2022). While the study does suggest that natural elements can benefit biodiversity, this is
a minor point in the broader discussion. The study primarily emphasizes the negative
impact of artificial grass on bird diversity at every level (alpha, beta, gamma) and the
need to reconsider its use in urban parks. Cornell's summary downplays the study's main
conclusion, which is that artificial grass significantly reduces bird diversity. Additionally,
the study surveyed 45 parks in eastern Spain, conducting detailed biodiversity analyses,
including statistical modeling. Cornell oversimplifies this by stating parks were surveyed
once for a period of two hours in the mornings," which makes it sound like a casual
observation rather than a rigorous scientific study.
On R0640-0641, Cornell’s response to the portion of Zero Waste Ithaca’s bibliography
concerning the failure of plastic recycling constructs a strawman argument by misframing
the issue. Rather than addressing the documented failure and environmental and public
health harms associated with recycling of plastic turf—such as microplastic pollution,
toxic chemical contamination, air pollution —they attempt to minimize the problem by
comparing synthetic turf waste to the total volume of plastic waste in the U.S. This
comparison is irrelevant and misleading, as synthetic turf pollution is not merely a matter
of weight but of persistent contamination, localized environmental damage, and the
absence of viable disposal solutions. Furthermore, Cornell provides no credible citations
for their disposal estimates, relying instead on figures that appear to originate from the
synthetic turf industry itself. Their claim that only 6,500 tons of synthetic turf are
disposed of annually is implausibly low, contradicting both industry and independent
research on turf field disposal. For detailed account of the numbers, see the separate tab
named “Recycling.”
On R0641-0642, Cornell repeats the same six references included in their April 2024
submission of Additional Materials, without offering any new evidence to support the
safety of artificial turf. Notably, since their April submission, Cornell has failed to
provide any additional materials beyond these twelve previously cited references. Of the
six references reiterated, two studies (Peterson and Schneider) are industry-funded, while
two EPA reports on tire-derived crumb rubber (TDCR) remain debated and only address
TDCR infill, neglecting many other environmental and health concerns associated with
artificial turf. Pavilionis et al.’s 2014 study is misrepresented limited in scope, and the
2018 Pronk study assesses safety only under controlled exposure conditions for sports
use. In contrast, a more recent study by Armada et al. (2022) for example highlights
broader environmental and cumulative human health risks, including microplastic
pollution and the persistence of hazardous chemicals in the environment. Armada’s
findings directly challenge the industry’s claims of "safe" rubber granules, particularly
when considering long-term environmental impacts and microplastic accumulation. It
makes one wonder where the “over 100 scientific, peer-reviewed, published studies”
Cornell makes reference to on page 4 of their Memorandum are.
On R0642, “Reports on Artificial Turf,” Cornell mislabels the section title—it should be
Reports by Environmental Organizations.” Cornell dismisses the substantial reports
from reputable groups—including Beyond Plastics, Plastic Pollution Coalition,
Earthjustice, Icahn School of Medicine at Mount Sinai, Environmental Working Group,
and PEER—as “impartial” while selectively citing the New York State Department of
Health (NYSDOH) fact sheet on synthetic turf with TDRC infill to misrepresent its
findings.
The fact sheet does not conclude that health risks are negligible—it acknowledges
uncertainties, data gaps, and the need for further research. NYSDOH explicitly states
that crumb rubber contains known carcinogens and potential risks, particularly for
children. Cornell distorts this by cherry-picking conclusions that align with its position
while ignoring warnings about chemical exposure and environmental concerns.
Cornell also downplays the severe heat hazards of synthetic turf, which the fact sheet
clearly addresses. Moreover, the NYSDOH report touches on chemical leaching, runoff,
and environmental persistence—issues Cornell conveniently omits. This selective
framing misleads the public and ignores the full scope of concerns.
On R0642, Cornell’s claim on Carmona et al. (2023) is misleading. The study actually
examines toxicity in recycled HDPE, not artificial turf, and was correctly placed under
the section of "Failure of Plastic Recycling," not under “Scientific Studies on Artificial
Turf.”
On R0642, Cornell describes Golijianin et al. (2024)’s study in this way:: “This study
reviewed NFL injury rates between natural grass and synthetic turf fields and concluded
that injury rates were higher when playing on synthetic turf fields. Given that NFL
natural grass fields are maintained in pristine playing condition, it would be anticipated
that injury rates on synthetic turf would be higher.” If even the NFL’s best-funded turf
fails to match natural grass, what makes Cornell think theirs will be any different?
On R0642, Cornell makes a false claim on Kole et al. (2023) as “based on a literature
review of mostly non-peer reviewed sources.” The peer-reviewed study was published in
Science of the Total Environment, following systematic review protocols (PRISMA
Preferred Reporting Items for Systematic Reviews and Meta-Analyses) and GRADE
Grading of Recommendations, Assessment, Development, and Evaluation).
On R0642, Cornell misspells the name of the author Watterson as Waterson. Cornell also
makes the false claim about this study as not peer-reviewed. Watterson’s 2024 study
was published in Scientific Reports and it would have undergone peer review prior to
publication. If Cornell University contends that this specific article was not
peer-reviewed, we would like to seek clarification from them regarding the basis of their
claim.
On R0642-0643, Cornell’s characterization of Winz et al. (2023) is misleading. The
study found that chromium exceeded the inferred safety limit on the surface of tire crumb
rubber playground tiles, while copper, arsenic, thallium, and antimony reached potentially
harmful levels within three years. Cornell’s claim that "no risk to children would be
present" because precipitation would wash metals away is not supported by the study.
Winz et al. explicitly state that metals are continuously released to the surface over time,
with some accumulating at concerning levels. The notion that rain will eliminate
exposure risks is not only speculative but ignores the persistence of contamination and
the potential for repeated dermal contact in playground environments.
On R0643, Cornell misrepresents the findings of Zuccaro et al.’s studies on tire-derived
crumb rubber (TDCR) from 2022 and 2023 (R0643). Zuccaro’s 2024 article provides a
more definitive analysis, highlighting the EU ban on TDCR infills and calling for similar
bans elsewhere due to microplastic pollution concerns. This study was co-authored with
the feature film “Dark Waters” real-life PFAS lawyer Robert Bilott. See the separate tab
Zuccaro” for details. Despite this, Cornell is still moving forward with plans to use
crumb rubber in one of its synthetic fields.
The rest of R0643 and R0644 dismiss items in our bibliography as “NGO websites,”
journalistic coverage,” or reports that “focus on PFAS and plastic; not specific to
synthetic turf”—as if synthetic turf is not plastic. These reports, however, are
well-researched and highly credible, with journalistic coverage that meets rigorous
investigative standards and reports that are as methodologically sound as peer-reviewed
studies. We selected only the most authoritative sources. On Bans and Moratoriums,
Cornell claims, “this content was addressed previously in this submission,” yet no such
response addressing these bans and moratoriums can be found. Cornell never actually
engaged with the issue of growing bans and moratoriums on synthetic turf but pretends
they did to dismiss the topic without proper discussion.
Cornell’s references on microplastics are entirely inadequate. They do not provide a single study
directly addressing microplastic pollution from synthetic turf, except for De Haan et al. (2023),
which they discuss only in response to our submitted bibliography rather than as part of their own
evidence. Despite this, they claim on page 21 of their Memorandum to have submitted
extensive documentation from scientific studies and consultant analyses addressing the topic of
microplastics.” However, the only reference they cite on that page is a two-page letter from Dr.
Frank Rossi (R0622-0623), which contains zero references and no scientific analysis.
Dr. Rossi has a documented conflict of interest (CoI) with the petrochemical company
Petro-Canada, a fact highlighted in a recent public comment on a related case. See the “Rossi”
tab for details. Additionally, the City Planning Board ignored a public comment submitted on
September 26 that outlined the flaws in Dr. Rossi’s claims about microplastic filtration and called
for a recall of the Negative Declaration. See the “On Filtration” tab for the full September 26
public comment.
2. Flawed and Inadequate Microplastics Mitigation Measures
Cornell’s natural grass turf expert Frank Rossi with CoI with fossil fuel company proposes
a 212-micron (0.212 millimeters) filtration system, which is woefully inadequate:
Microplastics and nanoplastics are often smaller than 1 micron.
Filtration only addresses water runoff but not airborne microplastics or particles
tracked away on shoes and clothing.
This was addressed in the 9/26 public comment.
Filtration systems themselves often contain PFAS, including PVDF, which are set to be banned
in Europe due to health risks.
Cornell ignores multiple studies we submitted citing synthetic turf as the significant source
of microplastic pollution (De Haan et al. 2023, Zhu et al. 2024)
The European Chemicals Agency’s (ECHA) warning that synthetic turf is the #1 source of
microplastic pollution in Europe. (ECHA 2020).
Toronto’s latest environmental study also flagged synthetic turf as the #1 contributor to
microplastic pollution. (Zhu 2024).
Cornell is located upstream from a major water source—meaning contaminants from
synthetic turf will flow into the local lake, creeks, and drinking water.
There is a substantial concern that microplastic contributes to HABs (Harmful Algal Bloom) in
Cayuga Lake according to the latest studies. (Koizumi, 2024)
3. Misleading Claims on PFAS Compliance
Cornell falsely claims that its “selected” synthetic turf will comply with New York’s
PFAS-in-carpets law, despite lacking key details:
No manufacturer or product has been selected—Cornell has no basis to confirm
compliance.
Independent testing has repeatedly found PFAS in turf products that claim to be
PFAS-free,” including in turf blades (Whitehead, 2023). Cornell has failed to respond
to multiple public comments raising this issue.
New York’s carpet law defines PFAS broadly (OECD-level), meaning even trace
amounts are significant. See the separate tab “OECD Definition of PFAS” for details.
It simply is not possible that their synthetic turf complies with the NYS law.
The EPA has declared that there is NO safe level of PFOA and PFOS—the only safe
level is zero. See the separate tab “OECD Definition of PFAS” for details.
PFAS chemicals such as PVDF and PVDF-HFP are commonly used in synthetic turf
manufacturing as slip agents to prevent blade defects during production.
Cornell fails to specify who will conduct independent PFAS testing, what the threshold for
compliance is, or if third-party oversight will be required.
Given the broad definition of PFAS, Cornell must be required to test for the entire class of
PFAS chemicals, not just select subsets.
4. Flawed Planning Board Process and Conflict of Interest
The planning board chair whose deliverance is given much weight in the memorandum on
page 7 had direct ties to Sasaki, a firm involved in synthetic turf projects.
He worked at Sasaki for 10 years in Watertown, Massachusetts, where Cornell’s
project consultant Trey Sasser also works. See the tab “Rossi” for details.
He did not recuse himself despite this clear conflict of interest. See the tab “Rossi” for
details.
The approval process was rushed, with only four board members present (barely making
quorum).
One member was brand new and likely did not review the nine months of submitted
scientific evidence.
The planning board’s discussion was limited only to PFAS and crumb rubber infill, ignoring
concerns about microplastics, plant-based infills, and other toxic chemicals.
5. Cornell’s Heavy Reliance on Dr. Frank Rossi’s 2-page “Analysis”
Cornell repeatedly cites a 2-page letter from Dr. Frank Rossi, a turfgrass expert with fossil
fuel ties.
The letter contains no references or citations and mentions European studies without
naming them.
Dr. Rossi is not an expert in microplastic pollution or environmental chemistry. He is a
natural turf grass specialist. His Ph.D. from Cornell is in Plant Science and he teaches
courses in horticulture, turfgrass science and food systems.
He has documented financial ties to Petro-Canada, creating a conflict of interest. (See
separate tab for Rossi for evidence).
6. Cornell’s Attempt to Dismiss Zero Waste Ithaca’s Standing
7 pages out of 30 of Cornell’s response focus on attacking Zero Waste Ithaca’s legal
standing under Article 78, instead of addressing substantive environmental concerns. ZWI is
incorporated.
Cornell argues that only direct users of the field—not the broader community affected by
pollution—should have standing.
The City Planning Board should recognize the public health and environmental threats posed
by this project.
7. Cornell’s Expansion Plans and Long-Term Impact
Cornell already has 9 synthetic turf fields on campus on our count - 7 existing, and 2 under
construction. See the separate tab for details.
A 2015 document confirms their plans to build at least five more synthetic turf fields as part
of their sports complex expansion.
Approving any more synthetic field will set a dangerous precedent for more.
Synthetic turf behaves like an invasive species, replacing natural ecosystems and spreading
pollution.
Conclusion
Cornell’s legal memorandum is misleading, selective, and inadequate in addressing the serious
environmental and health risks posed by its synthetic turf project.
Their “100+ studies” claim on page 4 of Cornell’s Memorandum is deceptive—they
submitted only 12 references, many of which are outdated or industry-funded.
They misrepresent microplastic risks and propose an ineffective 212-micron filtration
system.
Their claim of PFAS compliance is unverified, as no product has been selected or tested.
The planning board approval process was compromised due to conflicts of interest and lack
of expertise. They repeatedly cite Dr. Frank Rossi, who lacks relevant expertise and has
fossil fuel ties.
Their legal argument prioritizes procedural technicalities over public health and
environmental protection.
This case clearly meets the threshold under SEQRA for an Environmental Impact Statement (EIS)
because:
There is substantial scientific debate and uncertainty about the safety of synthetic turf.
Cornell is located upstream from a major water supply, increasing environmental risks.
New studies on microplastic pollution, PFAS, and toxic chemicals in plastics emerge
regularly—yet Cornell ignores them.
Cornell’s memorandum fails to justify their project on legal, scientific, and ethical grounds. The court
must require a full Environmental Impact Statement (EIS) to assess the real risks.
MICROPLASTICS:
Respondents assert that they have “submitted extensive documentation from scientific studies”
about microplastics. (NYSCEF Doc. No. 43 at 21.) However, this claim is misleading, as the
record indicates that only one letter from Respondents' own employee, Dr. Frank Rossi,
addressed microplastics. (R0622-23.) Dr. Rossi is a turfgrass expert with no demonstrated
expertise in plastic chemistry, microplastic pollution, or polymer science. His two-page letter,
which Respondents call an “analysis,” does not cite a single named study on microplastics and
focuses primarily on the necessity of synthetic turf rather than its environmental impacts.
In contrast, ZWI submitted over 70 pages of peer-reviewed studies from credible environmental
journals and authoritative sources demonstrating that synthetic turf is a major contributor to
microplastic pollution. (NYSCEF Doc. No. 20 at 33.) These studies confirm that microplastic
particles from synthetic turf persist in the environment, contaminate waterways, accumulate in
the food chain, and pose long-term ecological and human health risks. (Zhu et al. 2024, De
Haan et al. 2023, ECHA 2020.)
Cornell’s proposed mitigation measure—a 212-micron mechanical filtration system—is
scientifically meaningless. Microplastics and nanoplastics are often smaller than 1 micron—
hundreds of times smaller than Cornell’s filter threshold. (Park et al. 2022.) Scientists working
on microplastic removal target submicron filtration (under 1 micron) or, at minimum, 40 microns,
far below Cornell’s ineffective 212-micron threshold. (Chand et al. 2024.) Furthermore, Cornell’s
plan does nothing to prevent airborne microplastics—one of the primary pathways of human
exposure. The EPA’s 2024 findings confirm that synthetic turf users routinely carry microplastics
on their skin, shoes, and clothing, dispersing them into homes, cars, and water systems.
R1700.)
Compounding the risk, microplastics from synthetic turf contain water-soluble toxic chemicals—
including PFAS, VOCs, and heavy metals such as cadmium, mercury, and lead. (Silva et al.
2021.) New research indicates that microplastics combined with PFAS are even more toxic than
previously understood. (Huang et al. 2025.) While Cornell claims its turf will be “PFAS-free,” it
provides no manufacturer details, no accountability for independent testing and reviews, and no
threshold criteria to substantiate this claim. Under New York’s carpet law, PFAS is broadly
defined, as “a class of fluorinated organic chemicals containing at least one fully fluorinated
carbon atom,” aligning with OECD standards—making it nearly impossible for any synthetic turf
manufacturer to prove a truly PFAS-free product. (Wang 2021, NYS Open Legislation
https://www.nysenate.gov/legislation/laws/ENV/27-3301.)
The EPA in 2024 documented that the majority of people who had used synthetic turf fields
found synthetic turf infill on their person, in their cars, and in their homes after leaving the field.
R1700.) This demonstrates the difficulty—and near futility—of preventing microplastics from
spreading into the environment once synthetic turf is installed. The 2024 PEER study further
confirms that PFAS contamination from synthetic turf is transferred onto players' hands, with
levels significantly higher than those on natural grass fields. (PEER 2024.) Additionally, a June
2024 study in Environment International found that PFAS compounds can be absorbed through
human skin, reinforcing the risks of direct exposure. (Ragnarsdóttir, Abdallah, and Harrad
2024.) These findings directly contradict Respondents’ claims that PFAS exposure via synthetic
turf is negligible.
SEQRA requires agencies to take a “Hard Look” at environmental risks before issuing a
Negative Declaration. The Planning Board’s failure to meaningfully evaluate these concerns—
and its reliance on an unverified, two-page letter from a non-expert instead of extensive
independent research—renders its decision arbitrary and capricious. Given the overwhelming
evidence that synthetic turf contributes to microplastic and PFAS pollution, an Environmental
Impact Statement (EIS) is legally required.
AIR EMISSIONS AND VOCs.
Despite Respondents’ contentions, the record lacks scientific studies demonstrating a
consensus that emissions and VOCs from synthetic turf fields pose no health risks. Instead,
multiple studies show that synthetic turf releases harmful airborne pollutants, especially in
enclosed spaces.
Respondents cite a 2018 New York State Department of Health Guidance Document, claiming
that exposure to VOCs, SVOCs, and airborne particulate matter from synthetic turf is
insignificant” and comparable to natural grass. (NYSCEF Doc. No. 43 at 21-22.) However, they
fail to include the part of the study that states that when synthetic turf is installed indoors, VOC
and particulate concentrations are significantly higher than outdoor fields. (R3152.)
Recent studies further confirm the risks associated with airborne microplastics and VOCs. The
2023 Center for International Environmental Law (CIEL) report highlights the growing crisis of
airborne microplastics from synthetic turf, which are inhaled and linked to respiratory and
cardiovascular diseases. (CIEL 2023.) Additionally, studies such as Mohammed et al. (2023)
confirm that synthetic turf releases VOCs at higher levels in warmer temperatures, raising
cancer risks, particularly for children. (Mohammed et al. 2023.) Phthalates, commonly used as
plasticizers in synthetic turf backing and infill, are also released into the air, posing endocrine-
disrupting risks and linked to reproductive and developmental issues in children. (Negev et al.
2022.)
Indoor synthetic turf installations pose even greater risks. Studies such as Abad López et al.
2023) show that airborne microplastics in enclosed environments accumulate and are inhaled
at much higher rates due to limited ventilation. (Abad López et al. 2023.) These microscopic
plastic particles penetrate deep into the lungs, increasing risks of inflammation, chronic
respiratory diseases, and cardiovascular issues. (Aini et al. 2022.) The Huang et al. (2023)
study on EPFRs (environmentally persistent free radicals) in crumb rubber infill further confirms
that exposure can lead to oxidative stress and respiratory complications. Crucially, ventilation
systems do not effectively capture or neutralize these nanoparticles, allowing them to circulate
freely in the air.
Cornell’s memorandum selectively omits these risks while relying on outdated assessments and
misrepresenting studies. SEQRA requires agencies to take a “Hard Look” at environmental
impacts, yet the Planning Board dismissed peer-reviewed evidence on VOC emissions and
inhalation risks in favor of an incomplete summary from Respondents. This failure to
meaningfully engage with scientific research constitutes an arbitrary and capricious decision
requiring an Environmental Impact Statement (EIS).
B. The Negative Declaration Relies on the Respondent’s Future Actions Making It Conditional
The Planning Board's reliance on future actions and mitigation measures to justify foregoing an
Environmental Impact Statement (EIS) is legally impermissible. Respondents cite W.
Beekmantown Neigh. Ass’n Inc. and Merson v. McNally to argue that project modifications
made in response to public concerns do not amount to an impermissible conditional Negative
Declaration. However, these cases do not support the Planning Board’s failure to require an EIS
in this instance.
In W. Beekmantown Neigh. Ass’n Inc., the court upheld mitigation measures only because an
EIS had already been completed (861 N.Y.S.2d at 866)—a crucial distinction from the present
case, where no EIS was conducted at all. Similarly, in Merson v. McNally, the court found that
minor mitigation—such as adding an additional two feet of buffer space (90 N.Y.2d 742, 755
1995))—did not require an EIS. Here, however, the proposed mitigation measures—such as
stormwater filtration to prevent microplastic pollution—are not minor adjustments but central to
the project’s environmental impact.
Moreover, SEQRA regulations explicitly prohibit lead agencies from using mitigation measures
as a substitute for full environmental review where potential adverse environmental impacts
exist. Courts have consistently held that agencies cannot defer analysis by assuming that
mitigation efforts will fully eliminate environmental harm (Matter of Farrington Close
Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 205 AD2d 623, 626 (2d Dep’t
1994); Matter of Cannon v. Murphy, 196 AD2d 498, 501 (2d Dep’t 1993)). The Planning Board’s
Negative Declaration does exactly that—it assumes that mitigation efforts will be sufficient but
fails to require a full environmental assessment to determine whether they actually will be.
Courts have invalidated Negative Declarations where mitigation measures are treated as a
substitute for actual impact assessment rather than being incorporated into a properly reviewed
project. (See, e.g., Cathedral Church of St. John the Divine v. Dorm. Auth. of State of N.Y., 224
A.D.2d 95, 102-03 (3d Dep’t 1996) (holding that mitigation measures cannot be used to evade
SEQRA’s EIS requirement)). Unlike the minor modifications in Merson, the entire foundation of
Cornell’s microplastic and PFAS risk assessment is based on untested mitigation efforts that
were never subjected to an EIS review.
By relying on mitigation measures instead of requiring a proper environmental review, the
Planning Board’s decision was arbitrary, capricious, and in direct violation of SEQRA. The law
does not permit agencies to assume that mitigation will eliminate potential harms - it requires
them to analyze those harms first.
From:
To:
Cc:
Subject:
Sent:
Constance Stirling-Engman
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Synthetic Turf issue, Town Planning Board March 18, 2025
3/17/2025 4:22:32 PM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town Planning Board Members,
The August 2024 report from the University of Massachusetts Lowell confirms
that PFAS have been detected in all components of artificial turf, including
blades, backing, infill, shock pads, adhesives, and even product packaging. Despite
Cornell University’s claims that its field hockey turf is different because it lacks infill,
this report demonstrates that PFAS contamination is not limited to infill alone.
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO
materials. However, this study, conducted by a respected research center with full
citations and expert analysis, is highly relevant to the town planning board’s review.
Declaring a negative declaration without considering this research is a failure of due
diligence. It is also deeply problematic that Cornell seeks to control the narrative by
discounting high-quality investigative journalism and research from credible
organizations—especially in a rapidly evolving field where new findings emerge
constantly.
Additionally, some artificial turf manufacturers have marketed their products as
PFAS-free,” but testing in this report reveals PFAS were still found in those materials.
This raises serious concerns about the validity of PFAS-free claims and the broader
regulatory loopholes that allow these chemicals to go unreported.
I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their
synthetic turf products is PFAS-free. However, this guarantee does not inspire
confidence for several reasons. First, FieldTurf does not provide total fluorine (TF)
testing, which is critical for detecting hidden PFAS, including polymeric PFAS and
precursors. Second, they do not specify detection limits for their PFAS tests—without
knowing how sensitive their tests were, we cannot assess the credibility of their claim.
Third, their methodology likely focuses only on a small subset of PFAS chemicals,
ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this
statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free
certification.This raises an important question: What kind of PFAS-free guarantee does
TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning
board must obtain and critically evaluate TenCate’s PFAS-free claims, including their
detection thresholds, test methods, and whether they include total organic fluorine
TOF) and total oxidizable precursors (TOP) testing. Without this information, the
board has not taken the "hard look" required under SEQRA. Given that PFAS have
been found in artificial turf products marketed as "PFAS-free," it is reckless to assume
that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s
guarantee.Additionally, I want to note that these reports have been included in Zero
Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along.
It is disappointing that the town planning board is moving forward with a Negative
Declaration for the EIA despite these submissions, appearing to yield to political
pressure from Cornell University rather than prioritizing scientific integrity and the
protection of our community’s health and environment.Hereby, we have submitted this
evidence for your review, ensuring that the record reflects these critical findings, which
you are choosing to disregard as you move forward with a Negative Declaration.
Sincerely,
Constance Stirling-Engman
References:
1. Lowell Center for Sustainable Production, University of Massachusetts
Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf:
Academic, Municipal, and Other Testing Efforts. August
2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in-
Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18-
386957.pdf?rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0.
The compilation of PFAS testing from academic, municipal, and independent
studies confirms that PFAS have been detected in all components of artificial
turf, including turf blades, carpet backing, infill, shock pads, adhesives, and
even product packaging. Total fluorine (TF) testing consistently found
fluorine across various samples, with concentrations ranging from 16 to 661
µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated
coatings, or PFAS-based processing aids. Extractable PFAS tests detected
long- and short-chain PFAS in multiple studies, particularly fluorotelomer
alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf
fibers, and PFAS precursors in adhesives and shock pads. Municipal and
nonprofit-led testing further corroborates these findings, with PFAS measured
in stormwater runoff, installation materials, and artificial turf fields marketed
as ‘PFAS-free.’ These results highlight significant gaps in industry claims and
emphasize the need for stricter regulations and improved testing
methodologies to assess the full extent of PFAS contamination in artificial turf
systems.
2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the
Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth,
NH. October 22,
2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas-
statement-fieldturf-1.pdf
A supplier for FieldTurf/Tarkett Sports claims that their artificial turf
filaments/fibers are fluorine-free and do not contain PFAS, including PFOS,
based on manufacturing consistency and compliance with REACH
regulations. However, the declaration lacks total fluorine testing, does not
specify PFAS detection limits, and does not test the full turf system, meaning
polymeric PFAS or precursors could still be present. Additionally, there is no
independent third-party verification, making the PFAS-free claim
scientifically weak and incomplete.
3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A
Zero Waste Ithaca Bibliography. Updated March 16, 2025
https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-
s_4bfbmO26R-Q/edit?usp=sharing
Subject: TenCate’s Synthetic Turf: Pesticide Use, Microplastic Pollution, and ExxonMobil Ties
Contradict Cornell’s Sustainability Claims
Dear Town Planning Board Members,
Cornell University has selected TenCate as the manufacturer for its planned “PFAS-free” synthetic turf
field on Game Farm Road. However, the university’s claims of environmental sustainability are
contradicted by TenCate’s own maintenance guidelines and troubling industry practices.
First, despite Cornell’s repeated assertions that synthetic turf eliminates the need for herbicides, TenCate’s
2024 Maintenance Manual explicitly allows only the use of Spectracide and Roundup—both known
carcinogens—for weed control. This directly contradicts statements made by Cornell chemist Brett P.
Fors at the March 4, 2025, Town Planning Board meeting, where he falsely claimed that synthetic turf
requires no pesticides. The manufacturer’s own documentation proves otherwise. See Page 15 of the
manual of “Approved System Components.”
Second, TenCate’s artificial turf is demonstrably prone to fragmentation, releasing microplastics into the
environment. A video recorded on February 4, 2025, by Pamela Bond in San Jose, California, shows
TenCate’s Pivot synthetic turf failing within just three months of installation. Turf blades were
visibly breaking down, shedding microplastic fibers into the environment—undermining industry claims
that synthetic turf prevents pollution.
Third, TenCate’s partnership with ExxonMobil further exposes the company’s role in environmental
harm. TenCate sends used synthetic turf to ExxonMobil’s Baytown, Texas, facility for so-called
advanced recycling' (i.e., pyrolysis), a process widely criticized for inefficiency, high emissions, and
environmental justice concerns. As documented by Dr. Neil Carman in his June 25, 2024, letter to
the City of Ithaca Planning Board, communities near Exxon’s Baytown complex have been fighting
toxic pollution for decades. The addition of synthetic turf waste processing only exacerbates the
environmental burden on these already overburdened communities.
Additionally, TenCate’s home country, the Netherlands, is moving away from artificial turf, as evidenced
by the Eredivisie’s decision to ban synthetic turf starting in the 2025–26 season. This marks a major
shift in Dutch professional football, where all clubs in the Eredivisie and Keuken Kampioen Divisie will
be required to play on natural grass or hybrid pitches. The decision, made unanimously by the leagues, is
the result of a long-term transition that began in 2018 and aligns with broader European efforts to phase
out artificial turf. As a Dutch-based company, TenCate now finds its own country rejecting the very
product it promotes, signaling a growing recognition of artificial turf’s drawbacks, including concerns
over player safety, environmental impact, and game quality.
Cornell’s selection of TenCate as a synthetic turf supplier raises serious concerns:
No independent PFAS testing has been conducted on TenCate’s products under full public
oversight.
TenCate’s own manual permits herbicide use, refuting Cornell’s pesticide-free claims.
Documented premature degradation of TenCate turf contradicts industry promises about
durability and environmental safety.
TenCate’s involvement with ExxonMobil’s chemical recycling scheme ties Cornell’s project to
a deeply flawed and polluting industry practice.
The evidence is clear: Cornell’s claims about synthetic turf sustainability are misleading. The university
cannot ignore the environmental and public health consequences of choosing TenCate as its turf supplier.
Sincerely,
Analyse Adams
Food & Water Watch Volunteer
References:
Pamela Bond, John Mise Park, San Jose, CA: TenCate Pivot Turf Failure (Video, February 4,
2025). A video shared by a grassroots activist in California.
https://share.icloud.com/photos/06b1nGfaanJ6PyjxN0sXMdtNQ
Dr. Neil Carman, Letter to the City of Ithaca Planning Board, June 25, 2024.
https://drive.google.com/file/d/17Hjoae7HMpXo3ueK92Auq71sJXXhsDUT/view?usp=sharing
TenCate Americas, TenCate Pivot 2024 Maintenance Manual V1 (Dayton, TN: TenCate
Americas, 2024).
https://www.dropbox.com/scl/fi/povlnuhbuh5qy1lbjq5jx/TenCate-Pivot-2024-Maintenance-Manu
al-V1.pdf?rlkey=ui10g16wenrdrjgy05rpyeidk&st=5l74l8dw&dl=0
Alexander H. Tullo, "ExxonMobil Will Recycle Synthetic Turf," Chemical & Engineering News,
October 1, 2022.
https://cen.acs.org/environment/recycling/ExxonMobil-recycle-synthetic-turf/100/i35
James Bruggers, “In Houston, a City Council Member Questions ‘Advanced’ Recycling of Plastic
and a City Collaboration with ExxonMobil.” Inside Climate News. December 13, 2024.
https://insideclimatenews.org/news/13122024/houston-city-council-member-questions-exxonmob
il-plastic-recycling/
Eredivisie. "No More Artificial Turf in the Eredivisie from the 2025-26 Season." Eredivisie, May
28, 2024.
https://eredivisie.eu/news/no-more-artificial-turf-in-the-eredivisie-from-the-2025-26-season/.
Dear members of the Town of Ithaca Planning Board,
Cornell University makes high claims of having a Climate Action Plan that
puts it in the forefront of institutions of higher learning taking on the
challenges of dealing with climate change.
Should we not expect that its actions would follow its words?
It appears that it did not live up to its claims when it lobbied to build the
Meinig Field House and adjacent field using artificial turf, also known as
synturf.
Synturf has been documented by reliable scientific sources to contain forever
chemicals (PFAS), micro plastic particlesand other harmful substances that
make their way into the bodies of young athletes playing on them and into the
surrounding environment, thus affecting the residents of the town of Ithaca.
How is it that Cornell, a prestigious university with faculty members in the
sciences of world renown, would take on such a project as this based on the
advice of a firm with ties to the fossil fuel industry whose actions have been
key to causing the climate catastrophe we are currently enduring and that has
supplied Cornell with misinformation about their product?
Why then is Cornell continuing to rely on false information while proposing to
replace yet another grass playing field with synturf, this time the Game Farm
Road Field Hockey field?
Cornell’s recent claims make additional unreliable assertions. It claims that it
will somehow procure the first PFAS-free artificial turf product ever produced:
But Cornell can provide no evidence for that claim. The Board asked it to
provide 3rd-party testing to show the chemical composition of its product. It
could not provide that testing. Instead, it only provided its manufacturer's
claim that the product will not contain "intentionally-added PFAS." As the
Board knows know from its own correspondence with experts like Dr. Genoa
Warner, it is not enough to rely on manufacturer's claims. Just because
Cornell says its product will comply with NY State's Carpet Law does not
mean its product will be PFAS-free. All the evidence before the Board-- from
both the research literature and the applicant's own materials on the Meinig
Fieldhouse Project -- show PFAS in turf blades, foam backings, and/or bonding
agents. Will the Board reject all available evidence and instead swallow whole
Cornell's claim that it will somehow produce PFAS-free turf product: a claim
for which it could not provide the requested 3rd-party testing evidence?
Can the Planning Board buy Cornell’s “story” while ignoring what diligent,
well-informed members of the community have presented about its harms?
Can it in good conscience dismiss the extraordinary work of these citizens
who have, in essence, done much of the homework for it to provide
scientifically reliable information about synturf?
Does the planning board wish to be complicit in causing harm to the young
athletes who have no idea what health problems they are bound to experience
later in life?
Does the Planning Board bear no responsibility to the community members
who run similar health risks due to the PFAS and microplastics that will enter
the environment and ultimately affect their health?
How can the Town Planning board, charged with making decisions in the
interest of the health and well-being of its residents, accept the information
presented by Cornell without demanding an EIS?
Will the planning board swallow Cornell’s false claim that the Hockey field is
not related to the Meinig Field house project ( in a move known as
segmentation) to avoid the necessity to subject it to an EIS?
Why would the Planning Board hesitate for a moment to insist that this
project be subjected to the full SEQRA process.
To whom is the Planning Board responsible? Cornell, the corporation, or the
current and future residents of the town of Ithaca, including the Cornell
student athletes. Do you not have the moral duty to serve and protect them
all using the most effective tools at your disposal?
I sincerely hope that your answers to my questions will lead you to insist that
this project undergo an EIS before you would even consider to allow it to go
forward.
Respectfully yours,
Elisa Evett
Statement on Synthetic Turf and the Plastics Industry
Brian Eden, Policy Coordinator, Campaign for Renewable Energy
March 18, 2025
Thank you for providing thoughtful attention to my concerns. I wish to present a critical
argument against the proposed project involving synthetic turf and the increasing reliance of the
fossil fuel industry on plastics. The fossil fuel industry has actively promoted the plastics market
as a growth area to maintain profitability, using petrochemicals as a key feedstock for plastics
production. As the world transitions toward renewable energy and away from fossil fuels, the
industry has sought to sustain demand by expanding the plastics market. We must ask ourselves:
Would humans, on their own initiative, choose to replace natural vegetation with plastics?
This project is fundamentally unsustainable. It involves contaminating a green field with plastics
and other chemicals, exposing athletes to microplastics that will contribute to their already
growing lifetime body burden, and unnecessarily exacerbating greenhouse gas emissions.
Scientific research has increasingly demonstrated the dangers of microplastics.
As I referenced in an earlier submitted comment, a New York Times op-ed, Our Way of Life is
Killing Us, highlighted the widespread detection of microplastics in human blood, lungs, liver,
heart, and brain tissue. This project will undoubtedly contribute to this looming health crisis. Are
any Planning Board members willing to take action and slow the flow of plastics into our
environment?
Despite our concerns, our request for a meeting with the Athletic Director was denied. The
University's response suggested that the Planning Board was the only relevant party of interest to
them. In my experience, the University has been unwilling to engage or collaborate with the
community on critical environmental issues. As an educational institution, should it not be
Cornell’s responsibility to provide student-athletes with balanced information about this project?
Instead, these students and their parents appear completely unaware of the complex
environmental, health, and climate implications of this project. Additionally, some Board
members seemed to provide significant weight to the assertion that synthetic turf fields would
benefit athletes’ mental health. If this was such a determinative factor, why was no scientific
evidence presented to support this claim?
In an earlier comment, I also raised the issue of excess Scope 3 greenhouse gas emissions
resulting from the extraction of raw materials and the intense energy consumption required for
plastics production. Section 7(2) of the NY Climate Act requires state agencies to consider
whether their actions, including permits and other administrative approvals, are inconsistent with
or interfere with the attainment of statewide greenhouse gas emissions limits, and to provide
justification and mitigation measures if deemed inconsistent. This principle should be applied in
this review. However, the Planning Board did not even consider this issue when producing the
finding on Impacts on Energy in the SEQR Part 3 review. It is not surprising that a
predominantly privileged Board would disregard these emissions, as those most adversely
affected tend to live in disadvantaged communities. In the developed world, we protect ourselves
through infrastructure upgrades, technological advancements, and policy changes, while
disadvantaged communities often face greater vulnerability and require targeted support and
adaptation strategies. Historically, Americans have been among the planet’s major per capita
contributors of greenhouse gases.
Another concerning omission from this review is the lack of participation from Cornell’s Office
of Sustainability. Why has this office, which specializes in campus environmental matters, not
been engaged in any of these synthetic turf reviews conducted so far? Cornell’s own
sustainability vision states: “We envision Cornell University as a carbon-neutral, living
laboratory for sustainability innovation; a place where every Cornellian can make a positive
impact on social, environmental, and economic progress.”
While objective criteria exist for determining significant environmental impacts, the weight
given to criteria such as magnitude and duration, by Planning Board members may be subjective.
The review focuses on individual topics rather than on cumulative impacts. What is the
cumulative impact of many entities making incrementally harmful decisions? We are witnessing
the impending rollback of fifty years of environmental protections under the Trump
Administration, which dismissed climate science as a hoax. The Planning Board’s review of this
project seems to fall somewhere between this deregulatory stance and the expressed concerns of
the local environmental community. We offer a different perspective than the Trump
Administration—one grounded in scientific literacy and social responsibility. We urge the
Planning Board to aspire to apply these values in this review
For the third consecutive review of synthetic turf projects (including the Ithaca College project),
it appears that the Board is prepared to dismiss community concerns. Board members have yet to
demonstrate a full understanding of the science involved. Are we doomed to repeat this
controversial process indefinitely with each subsequent request to install a synthetic turf field?
The Board possess a crucial tool at its disposal: an Environmental Impact Study (EIS). The need
for such a study in the Town is infrequent, yet this project clearly demands one. New York State
has provided this tool for Planning Boards to apply in this type of complex circumstance. Why
does the Board continue to reject the use of this essential tool? When was the last time an EIS
was utilized by this Board? Why does the Board persist in disregarding the concerns of its own
community members? Board members should decide this crucial matter as if they were our
neighbors.
As the community’s last line of defense, I urge the Board to reconsider its approach, prioritize
environmental and public health concerns, issue a Positive Declaration, and conduct an
Environmental Impact Study before making any further decision to approve this project. The
stakes are too high to ignore the need for a more comprehensive review.
Dear Town Planning Board Members,
The attached August 2024 report from the University of Massachusetts Lowell confirms
that PFAS have been detected in all components of artificial turf, including blades,
backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell
University’s claims that its field hockey turf is different because it lacks infill, this report
demonstrates that PFAS contamination is not limited to infill alone.
However, this study, conducted by a respected research center with full citations and expert
analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration
without considering this research is a failure of due diligence. It is also deeply problematic that
Cornell seeks to control the narrative by discounting high-quality investigative journalism and
research from credible organizations—especially in a rapidly evolving field where new findings
emerge constantly.
I am so grateful for to see the studies that ZWI have provided our community from their
legitimate, scholarly research that exhibits how horrifying this turf project is.
CAN YOU LIFT YOUR HEAD OUT OF CORNELL’S DECEPTION AND SEE IT?
WE WILL NOT STAND FOR THIS!!!!!
Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. It’s
absolutely beyond the pale that this institution that proclaims itself as a leader in scientific
research would represent themselves in such a horrifying manner.
TRULY.
Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but
testing in this report reveals PFAS were still found in those materials. This raises serious
concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow
these chemicals to go unreported.
I appeal to each of you on this board who have shown your interest and dedication to
making Ithaca healthy and safe. I know who you are, and I want you to use your voice to
REQUEST a deeper study goes into this.
DO NOT let Cornell bully you!
I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic
turf products is PFAS-free. However, this guarantee does not inspire confidence for several
reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting
hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection
limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess
the credibility of their claim. Third, their methodology likely focuses only on a small subset of
PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more
hazardous compounds. Lastly, without third-party, independent verification, this statement is just
a self-reported manufacturer claim rather than a rigorous PFAS-free certification.
This raises an important question: What kind of PFAS-free guarantee does TenCate—the
manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and
critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test
methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors
TOP) testing. Without this information, the board has not taken the "hard look" required
under SEQRA. Given that PFAS have been found in artificial turf products marketed as
PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently
verifying TenCate’s guarantee.
I also want to note that these reports have been included in Zero Waste Ithaca's bibliography
under the "Independent Testing of PFAS" section all along. It is disappointing that the town
planning board is moving forward with a Negative Declaration for the EIA despite these
submissions, appearing to yield to political pressure from Cornell University rather than
prioritizing scientific integrity and the protection of our community’s health and environment.
And one last piece: Cornell also plans to do “independent” testing in addition to the
manufacturer’s “PFAS-free” guarantee, but the testing will be done before it leaves the
manufacturer, with zero specifications about testing method, threshold, etc - really confidence
inspiring, according to page 10 of Supplemental Materials Submission dated January 31, 2025.
Hereby, we have submitted this evidence for your review, ensuring that the record reflects these
critical findings, which you are choosing to disregard as you move forward with a Negative
Declaration.
Do what’s right, people. THIS REQUIRES A COMPLETE ASSESSMENT!
Sincerely,
Caroline Ashurst
Subject: Public Comment on Cornell University's Synthetic Turf Recycling Claims
Cornell University’s claim that its synthetic turf will be recycled at the end of its life is misleading and
lacks a credible plan. In the January 31st Supplemental Material Submissions (page 12), Cornell states
that it is "committed to recycling" and lists two possible facilities for processing the turf:
1. Turf Recycler in Rockland, Massachusetts – This facility does not even exist yet, meaning there is
no way to verify its operations, practices, or even if it will be functional when Cornell’s turf needs
disposal.
2. Return Reclamation Program in Dalton, Georgia – Dalton is notorious for PFAS contamination
lawsuits and is known as the "carpet capital of the world," a title linked to the widespread use of
PFAS chemicals in synthetic carpets—including synthetic turf. The city of Dalton itself has filed
lawsuits against major carpet manufacturers, alleging that their operations have contaminated the
local water supply with PFAS.
Recent legal actions in Dalton expose the environmental risks tied to synthetic turf recycling in this
region:
On December 10, 2024, the City of Dalton sued Shaw Industries, one of the largest carpet
manufacturers, for PFAS contamination in the municipal sewage system. See:
https://phillipslaw.com/pfas-lawyer/georgia-shaw-industries-and-3m/
Mohawk Industries, another Dalton-based manufacturer, has sued 3M and other chemical
suppliers, claiming they concealed the environmental and health risks of PFAS chemicals used in
carpet and turf production. See:
https://www.atlantanewsfirst.com/2024/12/10/erin-brockovich-you-have-pfas-contamination-its-b
ig-one/
Murray County, GA, has also filed a lawsuit against carpet manufacturers, holding them
responsible for PFAS water contamination. See:
https://www.atlantanewsfirst.com/2025/01/23/county-blames-chemical-maker-manufacturer-cont
amination/
Meanwhile, a Georgia state lawmaker has proposed House Bill 211 ("PFAS Receiver Shield Act")
to grant immunity to carpet manufacturers from litigation related to PFAS pollution, a move that
has drawn sharp criticism from environmental advocates. See:
https://www.atlantanewsfirst.com/2025/03/03/gop-lawmakers-want-carpet-manufacturers-protect
ed-contamination-lawsuits/ turf
Why is Cornell even considering a PFAS-contaminated region for its synthetic turf recycling? This raises
serious concerns about the university’s lack of due diligence and the credibility of its recycling
commitments.
This vague and unverified recycling plan is not confidence-inspiring, especially given the history of
misleading claims about artificial turf recycling. In the previous Meinig ‘Fieldhouse’ project with two
synthetic turf , Cornell had suggested sending turf to Artificial Grass Recyclers (AGR)—a company
whose listed locations do not appear to exist. Please see a separate pdf for my notes about AGR locations.
Investigations into AGR’s listed addresses found that many were either vacant lots, residential complexes,
or unrelated businesses.
Additionally, Cornell has suggested Returf in North Carolina, another facility that is hundreds of miles
away, raising logistical and environmental concerns. Transporting synthetic turf thousands of miles for
questionable recycling solutions does not align with sustainable waste management principles.
Cornell’s chosen turf brand, TenCate, further exposes the contradictions in its sustainability claims.
TenCate promotes chemical recycling of synthetic turf in Baytown, Texas—a facility fiercely opposed by
local communities due to its high emissions, toxic pollution, and environmental justice concerns.
Chemical recycling is not a proven or scalable solution for synthetic turf disposal, and the process itself
generates significant contamination. Another public comment was submitted on this issue.
Adding to the concerns is Cornell chemist Brett P. Fors, who spoke at the March 4 Town Planning Board
meeting, advocating for synthetic turf while failing to disclose his own conflict of interest. Fors has at
least one pending patent application for chemical recycling technology, making his endorsement of plastic
synthetic turf highly questionable. (See below screenshot, with a link for B.P.F.’s study and a note about
pending patent application).
https://www.nature.com/articles/s41586-024-08386-w#citeas
Moreover, his lab receives funding from the U.S. Department of Energy
https://as.cornell.edu/news/energy-center-receives-126-million-renewed-funding), which has been linked
to research benefiting the fossil fuel industry—a conflict recently exposed in a recent investigation by
Grist.
https://grist.org/accountability/energy-department-american-chemistry-council-chemical-recycling/)
Given the lack of a credible recycling plan, the significant conflicts of interest, and the environmental
justice concerns surrounding chemical recycling, Cornell’s claims about synthetic turf sustainability
should not be taken at face value. The Planning Board seems to have failed to inquire into these serious
issues while proceeding toward a negative declaration in the environmental impact assessment.
We strongly demand a full Generic Environmental Impact Statement (GEIS) to thoroughly evaluate the
long-term consequences of this entire Game Farm Road site project before any approval is granted.
Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical
findings, which you are choosing to disregard as you move forward with a Negative Declaration.
Sincerely,
Carver Hauptman
Additional References:
Butler, Megan. “Panel Asked to Hold Georgia’s ‘Carpet Capital’ Liable for Contaminated
Drinking Water.” Courthouse News Service. September 13, 2022.
https://www.courthousenews.com/panel-asked-to-hold-georgias-carpet-capital-liable-for-contami
nated-drinking-water/.
About a lawsuit on PFAS contamination in Dalton, GA, the “Carpet Capital of the world.”
Artificial Grass Recyclers
https://artificialgrassrecyclers.com/site-locations/
Site accessed in December 2024.
Opaque Operations - no phone number for any of the couple of dozens of locations except for
the three listed on the “Site Locations” page of AGR in Sacramento, CA, Rockwall, TX and
Peoria, AZ. You have to request for directions in order to find address of each location. And
when you dig a little deeper on Google Map to ascertain locations, we found out that they
actually do not have any locations in many of these places. We checked up to 6 of them and
they were all faulty addresses.
AGR, Media, PA
We tried to find information about the closest AGR location in PA, and a search on Google Map
for “artificial grass recycler” in Media, PA is supposed to be located at AGR, 101 E Baltimore
Ave, Media, PA 19063, USA according to the company’s page but when we checked Google
Map, it leads to US Post Office address. https://artificialgrassrecyclers.com/site-locations/
Checked on Dec. 2024)
AGR, Thurmont, MD
Same issue with AGR’s Thurmont, MD location … 15 E. Main Street, Thurmont, MD. is a closed
tavern.
AGR, Woodbridge, VA
Same issue with their 1761 River Bend Way, Woodbridge, VA 22192 location - it appears to be
a residential complex.
AGR, Smithfield, VA
Their 15 S Church St, Smithfield, VA 23430 location seems to be a lawn in a quaint
neighborhood with B&B and church nearby. We don’t see any office or recycling facility.
AGR, Fayetteville, NC
This location is an apartment complex called Edward’s Place.
AGR, Temecula, CA
44830 Vía Pino, Temecula, CA 92590
Seems like a personal residence rather than a recycling facility.
AGR, Murrieta, CA (Permanently Closed Location)
Shots from April 2024?
25800 Washington Ave
Murrieta, CA 92562-9748
951) 216-7282
APN#000227410
Property/tax records not found
Connection to Turf Distributors, Temecula (new ST; left over stock) Visit Website
Screenshot from April, 2021
AGR, West Sacramento
1876 S River Rd, West Sacramento, CA 95691
tel. 925-259-3474
tel. 855-409-4247
AGR, 4452 TX-276, Rockwall, TX 75032
See the tall piles of artificial turf languishing outdoors - in an enormous area according to the
Google Map.
Returf, North Carolina
1906 West Front Street
Statesville, NC 28677
https://returf.com
From:
To:
Cc:
Subject:
Sent:
Sasha K-R
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Letter from local Ellis Hollow residents opposing Artificial Turf
3/18/2025 10:48:41 AM
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March 16, 2025
Town of Ithaca Planning Board
215 N Tioga St.
Ithaca, NY 14850
Dear Members of the Town Planning Board,
We are writing to express our strong opposition to Cornell University’s plan to expand
synthetic turf fields in the adjacent area. As longtime residents of Ellis Hollow Road
and the operators of Edible Acres, a permaculture nursery, we are deeply concerned
about the environmental and public health risks posed by these artificial turf fields and
other developments in the area—particularly their contribution to PFAS contamination,
microplastic pollution, long-term ecosystem damage, and the broader harm caused
throughout the plastic lifecycle, both nationally and globally.
PFAS, also known as “forever chemicals” due to their persistence and accumulation in
the environment, pose serious risks to water, soil, and human health. No level of PFAS
exposure is considered safe, and even minute amounts build up over time,
contaminating our shared environment and threatening our community garden and
local water sources.
Cornell’s plan lacks meaningful long-term accountability. While they now claim only
three synthetic fields will be installed, without a Generic Environmental Impact
Statement (GEIS), there is no legal obligation preventing further expansion. Given the
university’s significant financial ties to fossil fuel companies and plastic research with
pending patents, we have little confidence in their commitment to true sustainability.
This project directly contradicts Cornell’s stated climate goals and will set a dangerous
precedent for other institutions.
This is an opportunity for the Town Planning Board to demonstrate its integrity and
leadership by rejecting a project that prioritizes corporate and institutional interests
over public health and environmental responsibility. Issuing a positive declaration for
an environmental impact assessment and requiring a GEIS will show that Ithaca is a
true beacon for environmental justice.
We urge the Town Planning Board to reject further synthetic turf development and
instead advocate for preserving this land as a natural area with trails and fields that
support biodiversity rather than plastic-covered landscapes. We stand in firm
opposition to this project alongside Zero Waste Ithaca and its allies and urge you to act
in the best interest of the public, not corporate expansion.
Sincerely,
Sean Dembrosky, Sasha Kellner-Rogers, & family
1175 Ellis Hollow Road, Ithaca, NY
Owner, Edible Acres
Subject: Public Comment: Protecting Bird and WildlifeHabitat from Synthetic Turf at Game
Farm Road
Dear Members of the Town Planning Board,
I am writing to express my concern regarding the planned installation of synthetic turf at
multiple locations in the Game Farm Road area. Recent observations have revealed this area to
be a critical habitat for various raptor species, including Red-tailed Hawks, Northern Harriers,
Rough-legged Hawks, Sharp-shinned Hawks, Cooper's Hawks, and Merlins. These birds
rely on the existing natural grasslands and semi-natural cover as a critical hunting ground,
preying on small mammals and birds that depend on the current ecosystem.
Scientific studies highlight the negative ecological impacts of artificial turf, particularly on avian
diversity. Research such as Sánchez-Sotomayor et al. (2022) published in Bird Conservation
International demonstrates that replacing natural grass with synthetic alternatives leads to a
significant decline in bird species richness, abundance, and overall biodiversity. Although
much of the research focuses on urban bird populations, the fundamental ecological principles
apply to raptors as well: the loss of natural habitat and associated food sources can lead to
a decline in these apex predators.
Cornell University in their Supplemental Materials Submission on January 31, 2025 falsely
claims on page 8 and 9 that the Game Farm Road site is not a habitat for threatened or
endangered species. The following raptor species observed in the Game Farm Road area will
likely be affected, of which three of them - Northern Harriers, Sharp-Shinned Hawks, and
Cooker ’s Hawks - are listed as Species of Special Concern or of Greatest Conservation Need
and Threatened in New York State:
Red-tailed Hawks hunt from perches or while soaring, capturing prey such as small
mammals and birds primarily on the ground.
Northern Harriers rely on both vision and hearing to locate small mammals in open
fields. This species is listed as a Species of Greatest Conservation Need and
Threatened in New York State.
Rough-legged Hawks hover and scan open terrain for rodents and other small animals.
Sharp-shinned Hawks and Cooper's Hawks specialize in hunting small birds in
semi-natural cover. Both species are classified as Species of Special Concern in New
York State, meaning they are at risk of becoming threatened or endangered without
continued protective measures.
Merlins are small falcons that prey on songbirds, which rely on a healthy, biodiverse
environment.
Northern Harrier
Sharp-Shinned Hawk
Cooper ’s Hawk
Furthermore, the latest agenda packet for 3/18/25 meeting revealed the Three Birds Orchid
triphora trianthophoros), a threatened species in NY, VT, ME, NH and endangered In MA,
extirpated in CT, was identified as potentially inhabiting the project area. The applicant, Cornell
University, asserts that the Three Birds Orchid is unlikely to inhabit the project site because it
requires beech forest, which they claim is absent. However, this assertion seems an
oversimplification and not entirely accurate. While the orchid thrives in moist, mature deciduous
woodlands, particularly beech-maple forests, it is not strictly limited to them. The species also
occurs in other deciduous forest types that provide deep leaf litter, well-drained organic-rich
soils, and minimal competing vegetation. Additionally, the orchid's presence is heavily
dependent on specific mycorrhizal fungi, which are not exclusive to beech forests. The
applicant’s dismissal of habitat suitability based solely on the absence of beech trees fails to
account for these broader ecological requirements.
A comprehensive field survey including adjacent forests by an independent ecologist is
necessary to determine whether the project site may, in fact, support the species rather than
relying on an unverified claim.
Three Birds Orchid
Replacing natural grass with synthetic turf, parking paving and other developments disrupts this
ecosystem by eliminating vital prey species for raptors such as rodents, insects, and small birds.
The implications extend beyond these birds of prey, affecting the entire local food web.
Additionally, synthetic turf and other development creates an unnatural, sterile environment that
lacks the soil-dwelling organisms necessary for maintaining biodiversity. Research such as
Bernat-Ponce et al. (2020) has shown that replacing semi-natural cover with artificial surfaces
reduces habitat suitability and trophic resources, leading to declines in bird populations.
Furthermore, Khalid et al. (2020) highlight how microplastics from artificial surfaces disrupt
soil ecosystems, altering nutrient cycling and affecting plant growth, which in turn impacts insect
populations that serve as prey for many bird species. (Note: Khalid et al. is conveniently
dismissed as irrelevant study by Cornell University among many others in Zero Waste Ithaca’s
bibliography in Cornell University’s submissions). Recent research has further demonstrated the
risks that synthetic materials pose to avian species. Tokunaga et al. (2023) found polypropylene,
polyethylene, and ethylene vinyl acetate microplastics in the lungs of wild birds in Japan,
providing direct evidence that birds inhale airborne microplastics. These same plastics are major
components of synthetic turf, yet Cornell dismisses this study as irrelevant because it does not
specifically focus on synthetic turf fields. This argument ignores the well-documented shedding
of synthetic fibers from artificial turf blades and other turf system components due to wear and
weathering, which can lead to inhalation and ingestion by birds and other wildlife. While
polypropylene, polyethylene, and EVA microplastics may come from multiple sources, synthetic
turf is a known contributor to microplastic pollution through abrasion, runoff, and atmospheric
dispersion. Given that raptors like Northern Harriers and Cooper ’s Hawks hunt in open fields,
they are particularly vulnerable to airborne contaminants that accumulate in their hunting
grounds. Dismissing this research disregards the broader implications of synthetic turf ’s
environmental impact on avian species.
Cornell's claim that there are "100 acres of natural space" surrounding the project site
February 21, 2025 Supplemental Materials submission, p. 8) deliberately obscures the
broader context: Cornell plans to develop the entire site with additional synthetic turf
fields, parking lots, and artificial structures. The current piecemeal approach to approvals
allows Cornell to evade a full Generic Environmental Impact Statement (GEIS) by avoiding
comprehensive scrutiny for the entire project around the site. Rather than developing all projects
at once potentially causing controversy, Cornell has strategically started development away from
residential areas, incrementally expanding synthetic surfaces while minimizing opposition at
each phase. The synthetic turf baseball field in the middle of the area was first, and now the
northernmost site on Game Farm Road is being targeted for the field hockey field. The long-term
plan for additional artificial turf, increased pavement, more lighting, and increased vehicular
activity will introduce noise pollution, light pollution, runoff contamination, and trash and litter
accumulation, all of which negatively impact wildlife beyond the immediate site.
It is also important to note that turf blades backing and shock pads are all sources of
microplastic and PFAS pollution. On that note, we noticed Cornell’s submissions conveniently
omitted Whitehead’s 2023 study, a full Ph.D. dissertation, which provides critical evidence of
PFAS contamination in artificial turf blades, analyzing 27 samples using multiple methods.
PFAS were detected in all samples, with a median concentration of 5.1 ng/g and a maximum of
41.7 ng/g, while organic fluorine measurements indicated the presence of fluorinated polymer
processing aids. Cornell instead cites and misrepresents Lauria et al.’s 2022 study, whose result
Whtiehead discusses in her dissertation. This is a subject for another comment, but is yet another
clear example of how Cornell University selectively reads and misrepresents studies from Zero
Waste Ithaca’s bibliography.
The sources referenced above are just a few examples of the extensive research available in the
carefully curated bibliography, which includes peer-reviewed literature on the environmental
impacts of synthetic turf. The ongoing pattern of misrepresentations of the studies and our
submissions is a great concern. Planning board members are strongly urged to consult the
original submissions and sources in our bibliography directly before making decisions based on
misrepresentations.
Given the strong scientific evidence indicating the detrimental effects of synthetic turf on bird
populations and broader ecosystems, we urge the Town Planning Board to reconsider this
proposal and prioritize conservation-minded alternatives – a call on GEIS. Maintaining natural
grass and investing in habitat preservation aligns with the broader goal of protecting biodiversity
and ensuring that species such as those listed above continue to thrive in the Game Farm Road
area.
Thank you for your time and consideration.
Sincerely,
Amina Mohamed
Ph.D. Candidate
Ecology and Evolutionary Biology
Cornell University
References:
Audubon Center New York. Northern Harrier (Circus cyaneus): Guidance for Conservation.
Accessed March 10, 2025.
https://greenelandtrust.org/wp-content/uploads/2022/03/Audubon-Northern_Harrier.pdf.
This document provides conservation guidance for the Northern Harrier, which is listed as a
Threatened species in New York State. It details the species' habitat preferences, hunting
behavior, and nesting habits, emphasizing its reliance on open grasslands and wetland
areas. The resource highlights ongoing conservation efforts and the importance of
maintaining suitable environments for this raptor ’s survival.
Bernat-Ponce, Edgar, José A. Gil-Delgado, and Germán M. López-Iborra. "Replacement of
Semi-Natural Cover with Artificial Substrates in Urban Parks Causes a Decline of House
Sparrows Passer Domesticus in Mediterranean Towns." Urban Ecosystems 23, no. 3
2020): 471–481. https://doi.org/10.1007/s11252-020-00931-w.
This study investigates the effects of urban park remodelling, specifically replacing semi-natural
substrates with artificial surfaces, on the abundance of House Sparrows in
Mediterranean towns. Results show that such remodelling reduces habitat suitability and
trophic (nutrition or feeding) resources, leading to a significant decline in sparrow
populations, emphasizing the need for urban planning measures to preserve biodiversity.
Cayuga Bird Club. “Reynolds Game Farm.” Accessed March 10, 2025.
https://sites.google.com/site/cbc14850/where-to-bird/reynolds-game-farm. This webpage
provides an overview of the Reynolds Game Farm, highlighting its role as a habitat for
various raptor species, including Red-tailed Hawks, Northern Harriers, Rough-legged
Hawks, Sharp-shinned Hawks, Cooper's Hawks, and Merlins. Notably, the Northern
Harrier is classified as Threatened in New York State, and both the Sharp-shinned Hawk
and Cooper's Hawk are designated as Species of Special Concern. The site has
historically hosted high concentrations of Red-tailed Hawks and continues to support
diverse raptor populations. This source is valuable in documenting the ecological
significance of the area and reinforcing concerns about the impact of synthetic turf
development on protected and at-risk species.
Khalid, Noreen, Muhammad Aqeel, and Ali Noman. "Microplastics Could Be a Threat to Plants
in Terrestrial Systems Directly or Indirectly." Environmental Pollution 267 (December
2020): 115653. https://doi.org/10.1016/j.envpol.2020.115653.This review examines the
potential threats posed by microplastics (MPs) to terrestrial ecosystems, focusing on their
impacts on soil and plants. It highlights how MPs alter soil physicochemical properties,
affect plant community composition, and potentially create toxicity through root uptake.
The study also explores how MPs disrupt nutrient cycling and the soil's
carbon-to-nitrogen ratio, emphasizing their long-term environmental risks. The authors
stress the limited understanding of MPs in terrestrial systems and call for further
research to address these gaps, particularly regarding their effects on ecosystem
functioning and biota.
New Jersey Department of Environmental Protection. "Rare Plant Profile: Triphora
trianthophoros (Three Birds Orchid)." April 2022.
https://www.nj.gov/dep/parksandforests/natural/heritage/docs/triphora-trianthophoros-thr
ee-birds-orchid.pdf.
New York State Department of Environmental Conservation. “List of Endangered, Threatened
and Special Concern Fish and Wildlife Species of New York State.” Accessed March 10,
2025. https://www.dec.ny.gov/animals/7494.html.
This webpage provides an official listing of endangered, threatened, and special concern
species in New York State. It identifies the Northern Harrier as a Threatened species and
the Sharp-shinned Hawk and Cooper ’s Hawk as Species of Special Concern. The
resource is valuable for understanding the legal protections afforded to wildlife at risk
and their conservation status within the state.
Ramstetter, Jennifer M. Triphora trianthophora (Swartz) Rydb. (Three-birds Orchid)
Conservation and Research Plan. New England Wild Flower Society, May 2001.
https://newfs-society.s3.amazonaws.com/documents/Triphoratrianthophora.pdf.
Sánchez-Sotomayor D, Martín-Higuera A, Gil-Delgado JA, Gálvez Á, Bernat-Ponce E.
Artificial Grass in Parks as a Potential New Threat for Urban Bird Communities.” Bird
Conservation International. Cambridge University Press, July 26, 2022.
https://doi.org/10.1017/s0959270922000119
This study demonstrates that replacing natural grass with artificial turf in urban parks in
eastern Spain negatively impacted bird diversity. Parks with artificial grass show reduced
species richness, abundance, and gamma diversity compared to parks with natural grass.
These findings highlight the harmful effects of artificial turf on urban bird communities
and its threat to bird conservation.
Tokunaga, Yurika, Hiroshi Okochi, Yuto Tani, Yasuhiro Niida, Toshio Tachibana, Kazuo
Saigawa, Kinya Katayama, Sachiko Moriguchi, Takuya Kato, and Shin-ichi Hayama.
Airborne Microplastics Detected in the Lungs of Wild Birds in Japan." Chemosphere
321 (April 2023): 138032. https://doi.org/10.1016/j.chemosphere.2023.138032.
This study revealed the presence of airborne microplastics (AMPs) in the lungs of wild
birds in Japan using µFTIR spectroscopy, marking the first evidence of AMP inhalation
in avian species. Common polymers such as polypropylene, polyethylene, and ethylene
vinyl acetate were found in the lungs, emphasizing the dual exposure risk of ingestion and
inhalation for birds in polluted environments.
Wang, M., Zhou, P., DuBay, S., Zhang, S., Yang, Z., Wang, Y., Zhang, J., Cao, Y., Hu, Z., He, X.,
Wang, S., Li, M., Fan, C., Zou, B., Zhou, C., and Wu, Y. “Assessing Microplastic and
Nanoplastic Contamination in Bird Lungs: Evidence of Ecological Risks and
Bioindicator Potential.” Journal of Hazardous Materials 487. April 5, 2025.
https://doi.org/10.1016/j.jhazmat.2025.137274.
This study provides evidence of airborne microplastic (MNP) contamination in the lungs
of birds, demonstrating the pervasive nature of MNP pollution and its ecological risks.
The research analyzed 51 bird species, finding microplastics in every lung sample tested,
with an average of 416.22 MP particles per gram of lung tissue. The detection of both
microplastics (MPs) and nanoplastics (NPs) underscores the scale of airborne plastic
pollution and its potential impact on respiratory health. Larger-bodied, terrestrial, and
carnivorous birds exhibited higher plastic burdens, indicating that ecological traits
influence exposure levels.
Whitehead, Heather D. Development of Analytical Methods for Highly Selective and Sensitive
Analysis of Compounds Relevant to Human Health and the Environment. PhD diss.,
University of Notre Dame, 2023.
https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Se
lective_and_Sensitive_Analysis_of_Compounds_Relevant_to_Human_Health_and_the_
Environment/24869502?file=43760148. Dropbox full pdf backup:
https://www.dropbox.com/scl/fi/73xaku3dwi0jjtgamnoe3/WhiteheadHD042023D-1.pdf?r
lkey=y871tnevcqk4r0kwlzd42qhke&st=ioc6xn65&dl=0.
This dissertation provides critical evidence of PFAS contamination in artificial turf
blades, analyzing 27 samples using multiple methods. PFAS were detected in all samples,
with a median concentration of 5.1 ng/g and a maximum of 41.7 ng/g, while organic
fluorine measurements indicated the presence of fluorinated polymer processing aids.
These findings confirm that PFAS are embedded in synthetic turf materials, raising
concerns about long-term environmental and human exposure risks.
Woelke, Dianne. Public Comment to The Town of Ithaca, NY, Planning Board. Safe Healthy
Playing Fields, Inc., March 4, 2025.
https://www.dropbox.com/scl/fi/aapcjpmjg2i2z0hqcalbz/Dianne-Woelke-Cornell-4-Mar-2
025.pdf?rlkey=chlldd7nj6ikchjlne2m2v5ac&st=dlwr0wk5&dl=0
This document, prepared by Safe Healthy Playing Fields, Inc., presents arguments in
favor of a full environmental review for the Cornell GFR Hockey Field project. It
highlights concerns regarding synthetic turf, including its environmental, health, and
financial impacts. The report cites various studies on microplastic pollution, toxic runoff,
and the presence of harmful chemicals in artificial turf. It also discusses legal and
regulatory considerations, emphasizing the need for transparency and accountability
from Cornell University.
From:
To:
Subject:
Sent:
Daniel Keough
Town Of Ithaca Planning; pbstaff@cityofithaca.org;
Plastic turf projects.
3/18/2025 11:58:11 AM
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department
Please require an Environmental Impact Assessment for all microplastic turf
projects, including Cornell University.
Why would they be allowed to bypass environmental review, for projects that
clearly have an environmental impact?
Daniel Keough
From:
To:
Subject:
Sent:
Sara Hess
Town Of Ithaca Planning
Comments on Synthetic Turf - Require an EIS!
3/18/2025 12:21:49 PM
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department
To members of the Planning Board:
I have looked at a lot of documentation by scientific researchers about the health
hazards of Synthetic Turf and microplastics. I understand that the research studies are
impossible for me, as a non-scientist, to fully comprehend.
I do not expect you to be able to read or understand or evaluate these studies either.
THEN, my question is this:
Why do you reject the option of requiring an Environment Impact Study, specifically
provided in public policy, to help with decisions with complex questions that must be
answered in order to go forward with assurance to the public? An EIS is the obvious and
ethical path for the Planning Board to take.
Sincerely,
Sara Hess
124 Westfield Dr,
Ithaca, NY
From:
To:
Subject:
Sent:
Margaret McCasland
Town Of Ithaca Planning
key points re: Cornell's artificial turf
3/18/2025 12:01:58 PM
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While I am on record with you as opposed to any use of artificial turf for playing fields
and feel strongly that you should declare the need for a GEIS, here are some key
conditions that should be mandated in ENFORCEABLE ways for any plan to be
seriously considered.
NOT in any order:
RECYCLING.Cornell should be able to show a contract for ecologically recycling the
type of turf and underlayments used. Promises of an intent to recycle are meaningless
is recycling is not a reasonable (and thus likely to be used) option.
NATURAL GRASS: The use of herbicides, pesticides and fertilizer can be very
polluting. However it doesn't have to be, and some experts at Cornell know who to use
minimal chemicals safely. This should be mandatory NOW and Cornell COoperative
Extension could be helping athletic and recreation departments around the state do so.
WATER FILL: Spraying water onto the field as "infill" instead of crumb rubber will
only increase the chance of polluting run-off. Also the water is likely to evaporate
quickly during extreme heat. I know little about this method, but a GEIS would be a
good way to learn more about its likely impacts.
No PFOA": Since the synthetic turf is made of flexible plastic, it contains a plasticizer
otherwise almost all plastics are brittle). There are many plasticizers out there, most
perhaps even all) of which are endocrine disruptors. Insist on knowing the exact and
COMPLETE type of plastic to be used, including whether there are any forms of PFAS
umbrella term). The type being proposed may not have PFOA in it, but it likely has
another problematic chemical.
Thank you for your careful consideration of the many factors. Please declare the need
for a GEIS.
Margaret McCasland
Town of Ithaca
PS: Cornell should show leadership within the NCAA and work to change the
regulation that women's field hockey MUST be played on synthetic turf. As a former
field hockey player, I still believe in the "home field advantage" that comes from using
actual grass.
From:
To:
Cc:
Subject:
Sent:
Madelyn Smith
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Opposition to Cornell’s Artificial Turf Projects
3/18/2025 4:37:58 PM
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To Whom It May Concern,
I am opposed to Cornell’s installation of new artificial turf fields on the basis of public
health concerns. If made, these installations would be some of the worst possible for
environmental and human health in Ithaca’s community and beyond, with implications on
Cornell’s political standing on environmental issues. Synthetic turf already contributes to
microplastic pollution in Cayuga Lake, and by further expanding Cornell sets a precedent
that critical environmental health issues are not a top priority. It is scientific fact that
artificial turf is linked to toxic waste, fossil fuel interests, and public health risks. Please
consider this as the town of Ithaca makes decisions impacting the future of its land and
people.
Sincerely,
Madelyn Smith
From:
To:
Cc:
Subject:
Attachments:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Request for Recall of Negative Declaration – Flawed PFAS Testing & New
Evidence
CTI.23-097B_Testing-Report_Pivot_1.5-12-year-warranty.pdf
3/19/2025 10:02:03 AM
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Dear Town Planning Board Members,
We are deeply disappointed by your unanimous decision to issue a Negative
Declaration for the Game Farm Road synthetic turf project, despite a significant
number of residents voicing their opposition and extensive evidence of environmental
harm submitted by the public prior to the meeting. We formally request a recall of this
determination before the finalization of the paperwork and submit the following
additional information for your record.
Cornell’s Misleading “Independent” Testing
Cornell claims that, in addition to the manufacturer’s guarantee, it will conduct an
independent, third-party” test of the turf "prior to leaving the manufacturer (pre-
shipment)" (January 31, 2025, Supplemental Materials Submission, p. 10). Far from
inspiring confidence, this arrangement is fundamentally flawed.
Testing conducted at the manufacturer’s own facility is inherently compromised,
allowing the manufacturer to control the process, sample selection, and potentially
even the lab conducting the analysis. This is not independent oversight—it is a pre-
approved PR maneuver disguised as science.
True independent testing must be conducted off-site, without manufacturer
involvement, using EPA-standardized methods (meeting or exceeding EPA Method
1633, available since 2021), with full public disclosure of all relevant details
immediately upon completion. Anything less is a mockery of legitimate environmental
review.
Multiple members of the public raised these concerns in their comments, yet the board
chose to ignore them and proceeded with the Negative Declaration.
New Evidence: TenCate’s Own Test Results Confirm PFAS in
Synthetic Turf
Test results from TenCate’s own manual confirm PFAS in their synthetic turf, directly
contradicting claims that it is “PFAS-Free” (see attached report).
Failure of Transparency in Cornell’s PFAS Testing
Multiple members of the public have raised concerns about the lack of transparency in
Cornell’s so-called “third-party” PFAS testing, yet the board has failed to require
independent, standardized testing or provide clarity on:
The specific testing methods used
The detection thresholds applied
The laboratory name and credentials
Whether independent review was conducted
When and how the public can access full test results
Testing should always be conducted by independent third-party laboratories using
appropriate testing techniques and parameters. Signed affidavits claiming “PFAS-Free”
are never acceptable.
Cornell’s claim that:
the turf manufacturer attests that no polyfluoroalkyl substances (or PFAS) chemicals
will be used in the synthetic material.”
This statement is meaningless without independent verification, yet Cornell and the
board are treating it as proof. It is not science—it is an unverified marketing claim.
Tactics Used to Generate False “PFAS-Free” Claims
We have observed a variety of misleading testing techniques used to create false claims
of “PFAS-Free” status:
Inappropriate test methods (e.g., soil or water testing instead of correct
solid/plastic testing methods).
Use of deionized water or methanol as a solvent, which does not properly extract
PFAS from plastics.
Setting Reporting Limits (RLs) too high, making it impossible to detect PFAS at
relevant levels (e.g., 590 ppt for PFBA and 290 ppt for other PFAS).
Failure to perform the Synthetic Precipitation Leaching Procedure (SPLP),
which simulates real-world PFAS leaching over time.
Omission of “J” values, which estimate PFAS concentrations below the
Reporting Limit but above the Method Detection Limit.
Despite these significant scientific concerns, the board has rubber-stamped not only the
manufacturer’s self-reported test—conducted without regulatory oversight—but also
Cornell’s so-called “independent, third-party” test, which will take place before the turf
even leaves the manufacturer’s site.
This failure to apply due diligence undermines public trust and disregards scientific
best practices for PFAS detection.
Additional Scientific Findings on Artificial Turf Toxicity
We urge the board to carefully review the following peer-reviewed study:
Siegel, Kyle R., Brooklynn R. Murray, Jeff Gearhart, and Christopher D. Kassotis.
In Vitro Endocrine and Cardiometabolic Toxicity Associated with Artificial Turf
Materials."
Environmental Toxicology and Pharmacology, September 6, 2024.
https://doi.org/10.1016/j.etap.2024.104562
https://www.sciencedirect.com/science/article/pii/S1382668924002023
This study examined both new and weathered artificial turf samples and found:
Stronger endocrine-disrupting effects in weathered samples, affecting androgen,
estrogen, and thyroid receptors.
Activation of the AhR receptor, which is linked to toxin processing and
carcinogenicity.
Toxic effects on heart cells in rats, raising serious concerns about potential
cardiometabolic harm in humans.
These findings reinforce the urgent need for rigorous environmental and health
assessments before allowing synthetic turf installation.
Demands & Next Steps
The board must immediately reopen SEQRA review and require proper PFAS testing
before finalizing the Negative Declaration. Failure to do so will confirm that this
decision was made without legitimate environmental review.
Ignoring this critical issue will:
Jeopardize public health and environmental safety.
Demonstrate outright disregard for meaningful public input.
Expose the board’s unwillingness to enforce legitimate environmental oversight.
This letter and supporting evidence must be logged as part of the official record.
Supporting Documentation
PFAS Test Report – TenCate Synthetic Turf
https://geosurfaces.com/wp-content/uploads/2024/07/CTI.23-097B_Testing-
Report_Pivot_1.5-12-year-warranty.pdf (pdf attached).
Sincerely,
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
TECHNICAL REPORT
Report Number CTI.23-097B Page 1 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Pivot™ by TenCate Overview Test Report (1.5” Version)
Client(s) Name Joe Fields
Charles Dawson
Client Detail TenCate America
1131 Broadway St. Dayton, TN 37321
Report Number CTI.23-097B
Revision Number &
Date 1.1 December 19th 2023
Reported by Dr C Young
Approved by
Scope of Testing /
Project
At the request of TenCate America a wide range of testing was undertaken on the
Pivot™ turf system.
Testing included the procedures commonly used both in the United States and
European turf markets including identification, physical, chemical, and performance
test methods.
Testing was conducted to the relevant norms and specification outlined in the
procedures below following the best practices outlined in ISO 17025.
Test Procedures &
Standards
The following testing has been undertaken on the TenCate Pivot™ turf system.
Identification Tests
ASTM D5793 Stitch and Gauge
ISO 1763:2020 Tufts Per Unit Area
ISO 2549:1972 Pile Length above Backing
ASTM D5823 Pile Height
ASTM D5848 Backing Weight, Pile Yarn Weight, and Total Weight
ISO 8543:2020 Mass Per Unit Area and Total Pile Weight
FIFA TM 0023 Decitex of yarn
FIFA TM 0025 Yarn thickness
ASTM D3218 Fiber Width and Thickness
Physical Tests
EN 12616:2013 Infiltration / Porosity
ASTM D3385 Water Permeability
EN 12230:2023 Tensile Strength
ASTM D5034-09 Breaking Load (Grab Tear Strength)
ISO 4919:2012 Tuft Withdrawal Force
ASTM D1335 Tuft Bind
EN 13746 Dimensional Stability (Water, Frost & Heated)
Chemical Tests
EN 12457-4 Leaching Heavy Metals
ASTM F2765-14 (2021) Total Lead Content in Synthetic Turf Fibres
TECHNICAL REPORT
Report Number CTI.23-097B Page 2 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
DIN 38414-17 Extractable Organic Halides (EOX)
Annex XVII No 1907/2006 PAHs (Polycyclic-Aromatic Hydrocarbons)
GLI Procedure E9-1/E9-3 PFAS (Total Fluorine Content)
Performance Tests
EN 12235 (FIFA TM001 & ASTM F1551) Ball Rebound Height
EN 12234 (FIFA TM003) Ball Roll Distance
EN 14808 (FIFA TM004A & ASTM F3189/F2569) Shock Absorption (AAA/AA)
EN 14809 (FIFA TM005A & ASTM F3189/F2157) Vertical Deformation (AAA/AA)
FIFA TM013 Energy Restitution (AAA)
ASTM F355-A Impact Attenuation (Gmax)
EN 1177 & ASTM F355-E Critical Fall Height (HIC)
EN 15301-1 (FIFA TM006 & ASTM F1551) Rotational Resistance
Wear / Sample Conditioning
EN 15306 Exposure to Simulated Wear (LISport Classic)
FIFA LISport XL Exposure to Simulated Wear (LISport XL)
EN 12229 Samples Preparation
EN 13744 Immersion in Hot Water
EN 13817 Exposure to Hot Air
EN 14836 Exposure to Artificial Weathering (UV)
Note: testing on the TenCate Pivot™ turf system was undertaken to a range of test methods
coving the procedures and standards from the USA and European regions. Some of these
methods have crossover in method but are reported separately for clarity and in the units
relevant to the specific region / procedure.
Product Details
The product tested was TenCate Pivot™
The system is described in Appendix A from the specification sheet provided by the
client.
Note: the turf product was tested with a combination of shockpads for performance
specifications which are outlined in the relevant results section to demonstrate the
performance of Pivot™ as part of turf system.
Test Conditions
The test samples were tested at:
23 ± 2 °C (73.4 ± 3.5 °F); and
50 ± 10 % relative humidity
Samples were conditioned for a minimum of 24 hours prior to testing.
In accordance with EN 15330-1 (and FIFA test protocol) samples were prepared for
testing in different conditions as below:
Irrigated / wet samples (mass of water equal to mass of system applied)
Heated to 50°C (122°F)
Cooled to -5°C (23°F)
Preparation of samples were undertaken in accordance with EN 12229
TECHNICAL REPORT
Report Number CTI.23-097B Page 3 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Test Results
The results are presented in Appendices as below:
Appendix B: Identification Tests
Appendix C: Physical Tests
Appendix D: Chemical Tests
Appendix E: Performance Tests
Discussion &
Conclusions
The TenCate Pivot™ turf system has been tested to a comprehensive range of
standards covering identification, physical, chemical and performance criteria.
The report outlines the results of the testing to provide TenCate with the required
information for their clients to make an informed decision on the turf product.
Additional testing can be undertaken upon request including bespoke relationships
to norms and requirements if needed.
TECHNICAL REPORT
Report Number CTI.23-097B Page 4 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix A – Pivot™ Specification Sheet (1.5” version)
TECHNICAL REPORT
Report Number CTI.23-097B Page 5 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix A – Pivot™ Specification Sheet (1.5” version)
TECHNICAL REPORT
Report Number CTI.23-097B Page 6 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix B – Test Results: Identification
Turf
Test Method Unit Description Result Comment
ASTM D5793 in” gauge 3/8 -
in” stitch rate 5.33 -
ISO 1763
sq m tufts per unit area 22,000 metric
sq yd tufts per unit area 18,395 imperial (yd)
sq ft tufts per unit area 2,050 imperial (ft)
ISO 2549 mm pile length 38 metric
ASTM D5823 in” pile length 1.5 imperial
ISO 8543
g / sq m total system mass 4,985 metric
g / sq m pile mass 3,925 metric
g / sq m primary backing mass 251 metric
g / sq m secondary coating mass 749 metric
ASTM D5848
oz / sq yd total system mass 150 imperial
oz / sq yd pile mass 119 imperial
oz / sq yd primary backing mass 7.5 imperial
oz / sq yd secondary coating mass 22.5 imperial
Yarn(s)
Test Method Unit Description Result Comment
ASTM D3218
FIFA TM 0025
microns
µm) 101
yarn A
XP
5,040/1)
microns
µm) 153
yarn B
Semi TxT
5,400/6)
microns
µm) 144
yarn C
TxT
7,200/10)
FIFA TM 0023 Dtex decitex of yarn
XP – 5,110/1
Semi TxT – 5,511/6
Txt – 7,151/10
denier is circa 10
lower than
Dtex
TECHNICAL REPORT
Report Number CTI.23-097B Page 7 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix C – Test Results: Physical Properties
Test Method Unit Description Result Comment
EN 12616 mm/h falling head infiltration test > 3,000 metric
ASTM D3385 in”/h falling head infiltration test > 100 imperial
EN 12230 N / mm tensile strength – MD 32 metric
tensile strength - CD 40 metric
ASTM D5034-09 lbs grab tear – MD 286 imperial
grab tear - CD 401 imperial
ISO 4919
N tuft bind 45 metric – target 30
N tuft bind after water age 44 metric – target 30
change 97 > 75 %
ASTM D1335 lbs tuft bind 10.2 imperial
EN 13746 % shrinkage (water, frost & heat) < 0.05 requirement < 1 % % extension (water, frost & heat) < 0.05
TECHNICAL REPORT
Report Number CTI.23-097B Page 8 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix D – Test Results: Chemical
Test Method Unit Description Result Comment
EN 12457-4 / ISO
11885 mg / kg compliance test for
leaching - metals
lead (Pb) < 0.005
cadmium (Cd) < 0.001
chromium (Cr) < 0.002
tin (Sn) < 0.005
zinc < 0.005
DOC < 0.001
mercury (Hg) < 0.00001
none-detectable
ASTM F2765-14 ppm total lead content in
synthetic turf fibres > 100 none-detectable
DIN 38414-17 mg / kg extractable organic
halides (EOX) < 20
none-detectable
allowable limit is
100 mg/kg
Annex XVII No
1907/2006 mg / kg
PAHs (polycyclic-
aromatic
hydrocarbons)
0.2 for each 18 PAHs
none-detectable
allowable limits is
20 mg/kg
GLI Procedure
E9-1/E9-3 PPM PFAS
a09: Fluoride < 0.5 ppm
F: Fluorine < 10 ppm
r19: Organic Fluorine < 10 ppm
None-detectable
Notes:
Test values often are not reported as zero the test method is only accurate enough to stipulate a ‘less than’
result. This value can be different for each specific substance or test method.
TenCate Pivot™ has been declared complaint with requirements of REACH within the European Union and
EPA / Prop 65 criteria in the United States.
TECHNICAL REPORT
Report Number CTI.23-097B Page 9 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix D – Test Results: Performance
Test Method
unit)
Sample
Conditioning
FIFA Quality
Range
Surface Combination
TenCate Pivot™
no pad)
TenCate Pivot™
GeoFlo (15 mm)
TenCate Pivot™
GeoFlo+ (15 mm)
TenCate Pivot™
GeoFlo+ (20 mm)
AAA (%)
Shock Absorbency
EN 14808
FIFA TM004A
ASTM F3189/F2569
Dry
55 to 70
58 61 63 66
Wet 58 62 64 67
50°C 59 62 65 68
5°C 57 60 63 64
LISport Wear
Classic 56 61 64 65
LISport Wear XL 57 61 63 65
AAA (mm)
Vertical
Deformation
EN 14809
FIFA TM005A
ASTM F3189/F2157
Dry
4 to 11
8.1 8.5 9.3 9.5
Wet 8.2 8.6 9.4 9.6
50°C 8.3 8.5 9.5 9.7
5°C 8.1 8.7 9.3 9.5
LISport Wear
Classic 8.0 8.4 9.3 9.9
LISport Wear XL 8.0 8.3 9.2 10.0
AAA (%)
Energy Restitution
FIFA TM013
Dry
20 to 50
not pass/fail)
32 31 29 28
Wet 32 30 28 27
50°C 33 32 29 27
5°C 32 32 30 26
LISport Wear
Classic 35 34 30 29
LISport Wear XL 35 33 31 29
Rotational
Resistance (Nm)
Grip
EN 15301-1
FIFA TM006
ASTM F1551
Dry
25 to 50
32
Wet 30
50°C 31
5°C 30
LISport Wear
Classic 38
LISport Wear XL 39
Impact Attenuation
Gmax
g)
ASTM F355-A
Dry
n/a FIFA
200 ASTM
165 STC
150 NFL
137 98 84 77
Wet 139 99 82 75
50°C 139 98 78 77
5°C 141 100 86 78
LISport Wear
Classic 142 99 85 81
LISport Wear XL 144 101 86 83
Critical Fall Height
HIC
m)
EN 1177
ASTM F355-E
Dry
n/a FIFA
1.3 WR
1.1 1.2 1.4 1.6
Wet 1.1 1.2 1.4 1.6
50°C 1.1 1.2 1.4 1.6
5°C 1.0 1.1 1.4 1.5
LISport Wear
Classic 1.0 1.2 1.4 1.6
LISport Wear XL 1.1 1.2 1.4 1.6
Ball Rebound
Height
m)
EN 12235
FIFA TM001
ASTM F1551
Dry
0.6 to 1.0
0.71 0.67 0.67 0.68
Wet 0.72 0.66 0.69 0.70
50°C 0.73 0.69 0.71 0.72
5°C 0.71 0.71 0.72 0.72
LISport Wear
Classic
0.76 0.73 0.72 0.73
LISport Wear XL 0.78 0.74 0.73 0.72
Ball Roll Distance
m)
EN 12234
FIFA TM003
Dry
4 to 10
6.5
Wet 6.8
LISport Wear XL 7.9
TECHNICAL REPORT
Report Number CTI.23-097B Page 10 of 10DateDecember19th, 2023
This information is confidential and was prepared by TenCate solely for the use of our client; it is not to be relied on by any 3rd party without TenCate prior written consent.
TenCate - Center for Turf Innovation
Appendix E – Pivot™ Product Photographs
From:
To:
Cc:
Subject:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Public Comment: Additional Misrepresentation of Scientific Studies in
Cornell’s Submission on Synthetic Turf
3/19/2025 11:26:31 AM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
To the Town of Ithaca Planning Board,
I am writing to address a serious misrepresentation in Cornell University’s
Supplemental Materials Submission dated February 21, 2025, specifically on page
8. Cornell falsely presents the Siegel et al. (2024) study and the U.S. EPA FRAP 2
2024) study as “companion studies” in an apparent attempt to undermine the findings
of Siegel et al. by misrepresenting the EPA study. This misleading framing falsely
suggests that the studies are directly related or that the EPA study negates the serious
concerns raised in Siegel’s research.
These studies are not connected in authorship, methodology, or findings:
The Siegel et al. (2024) study examines the toxicological effects of artificial
turf materials, finding that weathered turf samples increased bioactivity on
hormone receptors linked to endocrine and cardiometabolic disruption. This
raises significant concerns about synthetic turf’s potential health risks.
The EPA FRAP 2 (2024) study is an exposure characterization study,
assessing how athletes come into contact with chemicals from synthetic turf
but explicitly avoiding any toxicological or health risk assessment. It
confirms that players are exposed to hazardous substances, particularly in
indoor settings, but does not evaluate long-term health effects.
Cornell’s submission misrepresents the EPA study in two ways:
1. By falsely linking it to Siegel et al. as though the studies are complementary. In
reality, FRAP 2 does not assess toxicity, while Siegel et al. does.
2. By implying that FRAP 2 dismisses concerns about synthetic turf toxicity,
when in fact, the study acknowledges exposure risks but does not investigate
their health consequences.
This is an attempt to downplay the Siegel study’s findings, which raise serious
questions about the endocrine-disrupting and cardiometabolic toxicity of synthetic
turf materials. The Planning Board should reject this misleading framing and demand a
scientifically accurate and transparent evaluation of synthetic turf’s risks.
I respectfully request that this letter be added into the record together with my earlier
submission today, calling for the recall of the negative declaration for the
Environmental Impact Assessment (EIA). That letter included Siegel et al. (2024)
and urged board members to closely examine its findings.
This is part of an ongoing pattern of scientific misrepresentation by Cornell
University, which we have repeatedly raised concerns about in public comments
throughout this process. Despite these efforts, the board ignored our warnings and
proceeded to issue a negative declaration unanimously last night. This failure to
engage with the scientific evidence is unacceptable and undermines public trust in the
decision-making process.
Sincerely,
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
References:
Siegel, Kyle R., Brooklynn R. Murray, Jeff Gearhart, and Christopher D.
Kassotis. "In Vitro Endocrine and Cardiometabolic Toxicity Associated with
Artificial Turf Materials." Environmental Toxicology and Pharmacology.
September 6, 2024. https://doi.org/10.1016/j.etap.2024.104562
https://www.sciencedirect.com/science/article/pii/S1382668924002023
This study examines the potential health risks of artificial turf materials,
analyzing both new and weathered samples. The findings indicate that
weathered turf samples had stronger effects on various hormone receptors,
including androgen, estrogen, and thyroid receptors. Additionally, all turf
extracts activated a receptor linked to toxin processing (AhR), with some
causing heart cell toxicity in rats. These results raise concerns about the
endocrine and cardiometabolic effects of artificial turf materials, warranting
further investigation into their impact on human health.
U.S. Environmental Protection Agency. Synthetic Turf Field Recycled Tire
Crumb Rubber Research Under the Federal Research Action Plan: Final
Report, Part 2 – Exposure Characterization, Volumes 1 and 2. EPA/600/R-
24/044, April 2024. https://www.epa.gov/chemical-research/tire-crumb-
exposure-characterization-report-volumes-1-and-2.
This follow-up study known as known as FRAP (Federal Research Action Plan)
2 assesses human exposure to chemicals in synthetic turf fields through
inhalation, dermal contact, and ingestion. Findings confirm that players are
exposed to hazardous substances, particularly in indoor environments, though
the report does not conduct a full health risk assessment.
From:
To:
Cc:
Subject:
Attachments:
Sent:
Yayoi Koizumi
Town Of Ithaca Planning
pbstaff@cityofithaca.org
Formal Complaint Regarding March 4th Town Planning Board Meeting
Petaluma.pdf
3/20/2025 8:02:57 AM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Dear Town of Ithaca Planning Board Members,
We are writing to formally file a complaint regarding the handling of public
participation at the Town Planning Board meeting on March 4th, where Cornell
University President Michael Kotlikoff, Chemist Brett P. Fors, field hockey parents,
field hockey players, alumni, and the athletic director attended and spoke against Zero
Waste Ithaca’s submissions.
It is important for us to understand why Cornell’s President and affiliates were present
at the meeting, especially given that we were informed by a Town Planning Board staff
member that it was unclear whether we would be allowed to speak. As we understand
it, the "Persons to be Heard" section is typically reserved for public comments
unrelated to agenda items, and Cornell’s synthetic turf project was on the agenda that
evening—yet, no public hearing was scheduled.
When we inquired about whether we would have an opportunity to speak, we were told
it was uncertain. Given this, we invited others but had to make clear that we might not
be able to speak, out of respect for their time, since we could not be sure we would be
permitted to address the Board.
Yet, on March 4th, Cornell brought a significant number of representatives, including
high-ranking officials and students, who were able to speak at the meeting. We would
like to understand how and why this was possible, and why this level of participation
was seemingly coordinated when it was unclear if members of the public would be
allowed to speak.
We request that this email be entered into the public record as a formal protest
regarding the handling of public participation at the meeting.
Furthermore, because these correspondences pertain directly to procedural fairness and
transparency regarding the Negative Declaration (Neg Dec), we request that the Town
Planning Board proactively disclose any existing relevant records now, prior to
finalizing the Neg Dec, to ensure a complete and accurate record of the decision-
making process.
Additionally, I'm attaching Safe Healthy Playing Fields' public comment submitted to
the City of Petaluma, CA, as it contains relevant information and links to sources
regarding TenCate.
Thank you for your attention to this matter.
Sincerely,
Yayoi Koizumi
Zero Waste Ithaca | BYO - US Reduces
Founder | Co-Founder
zerowasteithaca.org
usreduces.org
P.S.: We are filing a separate FOIL request for email correspondences and records
related to the March 4th meeting between Town Planning Board members, staff, and
Cornell University representatives.
Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
3 Feb 2025 - Iem #8
Support Natural Grass Playing Field Alternative
Dear Mayor McDonnell, Vice-Mayor Nau, and Council Members Shribbs, Quint, Thompson,
DiCarli and Barnacle:
Thank you for the opportunity to submit comments on this item before the Council today. Safe
Healthy Playing Fields, Inc. (SHPFI) congratulates you on your strong dedication to the health
and safety of the residents of Petaluma and your commitment to the environment today and for
generations to come.
SHFPI is an all-volunteer 501-c-3 non-profit organization. We are committed to educating
communities, policymakers and elected officials about the health, safety and financial realities of
plastic fields versus grass fields and other synthetic surfaces for their parks and schools. Our
constituency ranges from concerned individuals to community and civic organizations, legal,
healthcare and science professionals, municipal leaders and state legislators.
The use synthetic turf is in direct conflict with the city’s Climate Emergency Resolution (2019)-
Integration of climate-friendly practices into projects and policies
Development of a REACH ordinance
Water conservation
Equity and Climate Justice
Carbon Sequestration and Mitigation
Zero Waste resolution adopted by county (2021)
We ask that you be aware that the California Department of Toxic Substances Control has
determined it will be bringing synthetic turf under regulation for per- and polyfluoroalkyl
substances (PFAS) that have been found in 100% of synthetic turf tested by academic,
non-profit organizations and independent commercial laboratories to date.1,2 They are also
2 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances
1 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive
Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University
of Notre Dame. https://doi.org/10.7274/bg257d30j3m
reviewing information on flame retardants, endocrine disrupting and neurotoxic phthalates,
antimicrobials, colorants, and more, and will make additional announcements at a future
date.3,4,5,6,7 Regulation will have major implications regarding disposal of these fossil fuel-based
petrochemical products as well as potentially the ability to replace these fields in the future near
future.
CA DTSC PFAS fact sheet
7 DTSC (27 Aug 2024). CalSAFER website
6 DTSC (27 Aug 2024). Presentation Slides
5 DTSC (27 Aug 2024). Meeting Agenda
4 DTSC (27 Aug 2024). Background Document
3 DTSC (27 Aug 2024). “Virtual Workshop on Candidate Chemicals in Artificial Turf” Meeting Recording
PFAS) in Artificial Turf: Academic, municipal, and other testing efforts.” Lowell Center for Sustainability,
University of Massachusetts, Lowell.
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2
0Other%20Tests%20Aug%202024_tcm18-386957.pdf
Chemicals of Concern in Synthetic Turf:
not comprehensive)
Phthalates
Latex
Polyvinyl chloride
Naptha
Siloxanes
Talc
Di/Isocyanates
Formaldehyde
Fungicides
Flame retardants
Coal fly ash
1,2-cyclohexane
dicarbonic acid
Dibutyltin
Ethylene glycol
Triclosan
Colorants
UV stabilizers
Anti-static
treatments
Per- and Polyfluoroalkyl Substances - PFAS:
NO ONE NEEDS MORE PFAS
It is imperative to accept independent peer-reviewed research, not industry sponsored research,
including that done by industry hired white-coats.8
On 23 May 2023, the American Association for the Advancement of Science’s Center for
Scientific Evidence in Public Issues (AAAS EPI Center), hosted a virtual event with a panel of
experts to discuss the drinking water standards announced by the US EPA in March 2023. The
panelists discussed the proposed regulations, the significance of setting the first PFAS national
drinking water standards, and the process the U.S. EPA has outlined for finalizing the rule.
SHPFI posed the question to international experts on PFAS, Drs. Linda Birnbaum and Jamie
DeWitt, as to the adequacy of the announced 4 ppt maximum for PFOA and PFOS limit in
drinking water’s ability to protect human and environmental health. Both clearly stated that this
level was not adequate for protection and that there is no safe level of PFAS. See HERE
@1:00:28
8 Gaber N, Bero L, Woodruff TJ (June 2023). “The Devil they Knew: Chemical Documents Analysis of
Industry Influence on PFAS Science.” Ann Glob Health.1;89(1):37.
https://pmc.ncbi.nlm.nih.gov/articles/PMC10237242/
Culled from public records, 32 PFAS have been found to date with independent testing:
D2-N-EtFOSAA
D3-EtFOSA
D9-EtFOSE
6:2 FTS
6:2 FTSA
7:3 FTCA
8:2 FTOH
12C2-4:2 FTS
13C2-6:2 FTS
13C2-8:2 FTS
GenX
D3-MeFOSA
D3-N-MeFOSAA
D7-MeFOSE
MTP
PFBA
PFBS
PFDA
PFHpA
PFHxA
PFHxS
PFNA
PFOA
PFOS
PFPeA
PFPrA
PFTrDA
PMPA
PPF Acid
PTFE
PVDF
R-EVE
The need to stop further PFAS exposure cannot be overstated. PFAS can cause multiple
reproductive disorders9 (including a 40% decrease in female fertility; a decrease of 62.3% total
sperm count in males)10; Crohn’s disease11; breast12, testicular, kidney13, prostate14 and liver15
15 Zhang, X., McGlynn, K., Sun, Q.. (ongoing research). “Perfluoroalkyl Substances (PFASs) and Liver
Cancer Risk in the United States; The Prostate, Lung, Colorectal and Ovarian (PLCO) Cancer Screening
Trial.” National Institutes for Health, National Cancer Institute. Accessed 25 Oct 2023.
https://cdas.cancer.gov/approved-projects/2555/
14 Messmer, M.F., Salloway, J., Traviss, N.. 2022. “Risk of Cancer in a Community Exposed to Per- and
Poly-Fluoroalkyl Substances.” Environmental Health Insights; Feb 2022: 16.
https://journals.sagepub.com/doi/10.1177/11786302221076707
13 Steenland, K., Windquist, A.. 2021. “Review article: PFAS and cancer, a scoping review of the
epidemiologic evidence.” Environmental Research; 194: 110690.
https://www.sciencedirect.com/science/article/abs/pii/S0013935120315899
12 Breast Cancer Prevention Partners (undated). “PFAS Forever Chemicals (also PFOA, PFOS).” Last
updated 24 June 2020. https://www.bcpp.org/resource/pfas-forever-chemicals-pfoa-pfos/
11 Xu, Y., Li, Y., Scott, K., et al 2019. “Ulcerative colitis, Crohn’s disease and other inflammatory bowel
disease in a population with high exposure to per- and polyfluoroalkyl substances through drinking water.”
Abstracts from the 2019 Annual Conference of the International Society of the International Society for
Environmental Epidemiology, August 25-28 2019, Utrecht, the Netherlands: Oct 2019; 3; 449. PFAS,
Ulcerative Colits, Crohn’s Disease
10 Levine, H., Jørgensen,N., Martino-Andrade, A., et al. 2023. “Temporal Trends in Sperm Count: A
Systematic Review and Meta-Regression Analysis of Samples Collected Globally in the 20th and 21st
Centuries.” Human Reproduction Update: 29 (2); 157–176.
https://academic.oup.com/humupd/article/29/2/157/6824414?login=false
9 Rickard, B.P., Rizvi, I., Fentond, S.E.. 2022. “Per- and Poly-fluoroalkyl Substances (PFAS) and
Female Reproductive Outcomes: PFAS Elimination, Endocrine-Mediated Effects, and Disease.”
Toxicology; 465,153031. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8743032/
cancers. They cross the blood-brain barrier and are related to Autism Spectrum Disorder16,
Attention Deficit Hyperactivity Disorder17, increased deaths from Parkinson’s and Alzheimer’s
diseases18; immunological effects19; increased serum cholesterol20; effects on infant birth
weights21; impaired glucose metabolism, insulin resistance, dyslipidemia and adiposity (obesity)
in children and adolescents22; thyroid hormone disruption (including neonatal)23 and thyroid
cancer.24 Because they are bioaccumulative, PFAS exposure can impact multiple generations.
Babies are being born pre-polluted with PFAS25 and microplastics.
25 Society of Toxicology. 2021. “Understanding Developmental Immunotoxicology and the
Effects of PFAS.” SOT TV Interview with Jamie DeWitt, PhD. https://vimeo.com/563823549
24 Messmer, M, Salloway, J, Traviss, N (11 Feb 2022). Risk of Cancer in a Community Exposed to Per-
and Poly-Fluoroalkyl Substances. Environmental Health Insights.
https://journals.sagepub.com/doi/10.1177/11786302221076707
23 Coperchini, F, Croce, L, Ricci, G, et al. 2021. “Thyroid Disrupting Effects of Old and New Generation
PFAS.” Front Endocrinol (Lausanne); 11: 612320.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7851056/
22 Goodrich, J.A., Walker, D.I., He, J.. 2023. “Metabolic Signatures of Youth Exposure to Mixtures of
Per- and Polyfluoroalkyl Substances: A Multi-Cohort Study.” Environmental Health Perspectives;131(2).
https://ehp.niehs.nih.gov/doi/10.1289/EHP11372
21 Gao, Y., Luo, J., Zhang, Y., et al. 2022. “Prenatal Exposure to Per- and Polyfluoroalkyl Substances
and Child Growth Trajectories in the First Two Years.” Environmental Health Perspectives; 130(3).
https://ehp.niehs.nih.gov/doi/10.1289/EHP9875
20 Li,Y., Barregard, L., Xu, L., et al.. 2020. “Associations between perfluoroalkyl substances and serum
lipids in a Swedish adult population with contaminated drinking water.” Environmental Health: 19(33).
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7071576/
19 Collaborative for Health and Environment Adverse (2 Dec 2020). “Effects of PFAS on Immune System
Health: Complicating recovery during the COVID-19 Pandemic.”
https://www.healthandenvironment.org/webinars/96552
18 Brown-Leung, J.M., Cannon, J.R.. 2022. “Neurotransmission Targets of Per- and Polyfluoroalkyl
Substance Neurotoxicity: Mechanisms and Potential Implications for Adverse Neurological Outcomes.
Chem Res Toxicol; 35(8):1312-1333. https://pubmed.ncbi.nlm.nih.gov/35921496/
17 Kim, J.I., Kim, Lee, Y.A., et al. 2023. “Association Between Early-Childhood Exposure to
Perfluoroalkyl Substances and ADHD symptoms: A Prospective Cohort Study.” Science of The Total
Environment: 879; 163081. https://www.sciencedirect.com/science/article/pii/S004896972301700X
16 Oh, J., Bennett, D.H., Calafat, A.M.. 2023. “Prenatal exposure to per- and polyfluoroalkyl substances
in association with autism spectrum disorder in the MARBLES study.” Environ Int Journal: 171:107662.
https://pubmed.ncbi.nlm.nih.gov/33387879/
Recent research has identified an age-related risk for cancer for children and
adolescents who play on synthetic turf.26 PFAS has been found to be dermally absorbed, as
well.27
Of high significance, a study done by the Kassotis Lab (Wayne State University, Detroit, MI) in
conjunction with The Ecology Center (Ann Arbor, MI), “In vitro endocrine and cardiometabolic
Testing should always be done by independent third-party laboratories using appropriate testing
techniques and testing parameters. Signed affidavits claiming “PFAS Free” are never
acceptable. We cannot emphasize this strongly enough.
the turf manufacturer attests that no polyfluoroalkyl substances (or PFAS) chemicals
will be used in the synthetic material.”
We have a noticed a variety of techniques used to generate false claims of “PFAS free”:
Inappropriate test methods (i.e. soil or water testing instead of method for solids/plastic)
Use of deionized water or methanol as a solvent
Setting Reporting Limits (RLs) too high (limits are 590ppt for PFBA and 290ppt for other
testable PFAS)
Not doing Synthetic Leaching Precipitation Procedure (SPLP) to age sample(s)
J” values not reported (the estimated value less than the Reporting Limit (RL) but
greater than the Method Detection Limit (MDL))
27 Ragnarsdóttir, O, Abdallah, MAE, Harrad, S (June 2024). “Dermal bioavailability of perfluoroalkyl
substances using in vitro 3D human skin equivalent models.” Environment International; (188), 108722.
https://www.sciencedirect.com/science/article/pii/S0160412024003581#ak005
26 Mohammed, AMF, Saleh, IA, Abdel-Latif, NM (29 Mar 2023). “Hazard assessment study on organic
compounds and heavy metals.” Heliyon: (9), 4, e14928
https://doi.org/10.1016/j.heliyon.2023.e14928
TenCate Pivot testing data28
PFAS should be tested in parts per trillion (ppt), not parts per million (ppm). Independent and
academic labs are able to test at 2 ppt. In the above example (TenCate’s Geosurfaces Pivot
product), fluorine was found by their proprietary laboratory. 10 ppm is the equivalent of
10,000,000 ppt. The safe level of PFAS is ZERO.
There is no indication in the above document that the appropriate EPA method 1633 was used.
Please be aware that this method can only test for some 40 PFAS chemicals out of over 16
28 TenCate (Dec 2023). “Pivot™ by TenCate Overview Test Report (1.5” Version). TenCate Center for Turf
Innovation, G. van der Muelenweg 2 • 7443 RE Nijverdal
The Netherlands TenCate Pivot testing data
thousand.29 Method 1633 has been available since 2021.The above testing appears to have
been done in late 2023. Also, absence of proof is not proof of absence.
TenCate Pivot testing data27
Claims of compliance with US EPA and CA Proposition 65 criteria are meaningless. CA Prop.65
only lists a handful of PFAS and requires businesses to comply with notifications of chemicals
on the list to purchasers, and begs the legal question of whether manufacturers are notifying
purchasers of the multiple chemicals in their products that are on the Prop. 65 list.
One of the over 16 thousand PFAS, PFOS was found on the hands of young soccer players
who played on synthetic turf in a small pilot study in San Diego in the summer of 2023.30 That
study is currently being replicated by the Kassotis Lab, Wayne State University, with 50 student
athletes and multiple playing fields.
Of high significance, a study done by the Kassotis Lab (Wayne State University, Detroit, MI) in
conjunction with The Ecology Center (Ann Arbor, MI), “In vitro endocrine and cardiometabolic
30 Amenabar, T (Mar 2024). “Study eyes safety of turf fields for kids: Scientists team up with San Diego
Surf soccer club to discover if ‘forever chemicals’ pose risk.” San Diego Union Tribune, originally
published in the Washington Post.
https://enewspaper.sandiegouniontribune.com/infinity/article_popover_share.aspx?guid=7f93edcb-cd5b-4
f9d-b8e4-ed57343daefc&share=true
29 US Environmental Protection Agency (updated Dec 2024). CWA Analytical Methods for Per- and
Polyfluorinated Alkyl Substances (PFAS) CWA Analytical Methods for PFAS
toxicity associated with artificial turf materials” published in the October 2024 edition of
Environmental Toxicology and Pharmacology, demonstrates the cytotoxic effects of chemicals in
synthetic turf to endocrine organs and cardiac development and function. This study also
demonstrates the importance of looking at combined chemical exposures associated with a
given product.31 No one is ever exposed to one chemical- certainly not with plastics and
definitely not with synthetic turf. A video of Dr. Kassotis discussing this pivotal research at the
Sept. 2024 New York University, Langone Health symposium on plastics research is available
HERE: 32
With chemicals of concern in both children’s products and synthetic turf currently under review
by the California Department of Toxic Substances ControlCA (DTSC), it is reasonable to expect
markedly lower acceptable limits for PFAS and additional chemicals.
If the industry were able to eliminate PFAS from its products some day, it would still be plastic,
with myriad toxic, carcinogenic and hazardous chemicals. Of the 16 thousand chemicals found
in plastics, less than one percent can be considered non-hazardous.33 Synthetic turf is made of
mixed plastics. There are over 16,000 known chemicals found in plastics. Of the known
chemicals, 4,200 are considered “highly hazardous” to human and Per- and polyfluoroalkyl
substances (PFAS) are but one of the 15 categories of chemicals of concern in plastics.
These chemicals add disease burden and health care costs. In the United States, for 2018, the
attributable cost of plastics to disease and health care related costs was $249 billion; for PFAS
alone, it was $22.4 billion.34 The societal cost globally is estimated at $16 trillion USD annually
for PFAS clean ups and health care for impacted individuals.35
35 Staff writer (23 May 2023). “ChemSec identifies the top 12 PFAS producers in the world and reveals
shocking societal costs. PRESS RELEASE: The global societal costs of PFAS chemicals amount to €16
trillion per year.” ChemSec, Norway.
https://chemsec.org/chemsec-identifies-the-top-12-pfas-producers-in-the-world-and-reveals-shocki
34 Trasande, L, Krithivasan, R, Park, K et al (Feb 2024). “Chemicals Used in Plastic Materials: An
Estimate of the Attributable Disease Burden and Costs in the United States.” Journal of the Endocrine
Society: (8), 2. https://doi.org/10.1210/jendso/bvad163
33 Wagner, M, Monclús, L, Arp, HPH et al (Mar 2024). “State of the science on plastic chemicals:
Identifying and addressing chemicals and polymers of concern.” PlastChem, Norway
https://plastchem-project.org
32 Kassotis, C (23 Sep 2024). “Endocrine and cardiometabolic toxicity of artificial turf associated
materials.” Video of presentation at NYU Langone Health symposium on plastics research.
https://www.youtube.com/watch?v=q8MDXyQKnFA
31 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic
toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111),
104562. https://doi.org/10.1016/j.etap.2024.104562
Early chemgrass, made without PFAS, was brittle. The synthetic turf industry has had 60 years
to self-regulate. Were it capable of doing so, it would not be under review for regulation by
DTSC at this time.
Chemicals are regulated at the state and federal levels. We urge you to not engage with any
industry attempting to establish testing parameters of any chemicals, including
limits…particularly important when their interest is keeping you, and taxpayers, on the hook for
additional sales and future replacements. Consider the chaos that would ensue if each city,
county or board of education were to adopt different parameters for testing. The industry knows
their product is coming under regulation in California. They know that ordinances have been
adopted and proposed up and down the state, across the country, and around the globe. They
know that legislation will come, as it has in several other states.
Further, it is necessary to quickly transition away from all synthetic turf and not give any sanction
to its use in any form due to all toxic, carcinogenic and hazardous chemicals, not solely PFAS.
It’s time to turn off the tap on use of unnecessary plastics generally. Synthetic turf falls within
this category.
Heat & Heat Island effect:
Plastics get extremely hot and pose a risk for thermal burns, sometimes significant enough to
require hospitalization. Synthetic turf can readily become much hotter than asphalt, reaching
temperatures of 1600F to 1800F (regardless of infill type) and have even reached well in excess
of 222.8oF (106oC). At a surface temperature of 118°F, a first-degree thermal burn occurs in 15
minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of
140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.36
High temperatures pose a serious risk for heat illness. One of the predisposing factors for heat
illness are prescription drugs for treatment of attention deficit hyperactivity disorder (ADHD),
which can be caused by PFAS chemicals found in plastics.37 ADHD affects approximately 7% of
6- to 11 year olds, and has been declared a serious public health problem.
Children are not small adults. They are more readily impacted by heat illness due to:
Heat production – Children have higher metabolic rates than adults which leads to
higher production of more heat.
37 Forns, J, Verner, MA, Iszatt, N (6 May 2020). “Early Life Exposure to Perfluoroalkyl Substances (PFAS)
and ADHD: A Meta-Analysis of Nine European Population-Based Studies.” Environ Health Perspect;
128(5):57002. https://ehp.niehs.nih.gov/doi/10.1289/EHP5444
36 Moritz AR, Henriques FC Jr (1947). Original source. “Studies of thermal injury II: The relative
importance of time and surface temperature in the causation of cutaneous burns.” Am J Pathol.; 23:
915-941. http://www.antiscald.com/index.php?route=information/information&information_id=15
Body surface area – Younger children absorb more heat because they have a greater
body area to body mass ratio. For older children and teens, increased body fat and low
fitness levels are contributing factors.
Blood circulation – Children are less able to cool their body temperature by shunting their
blood from their body core to their body surface due to lower cardiac output and smaller
blood volume.
Sweat production – Children produce less sweat per gland and sweat at higher body
temperatures than adults.
Fluid replenishment – Children are less likely to self-regulate hydration if unsupervised.
Children experiencing heat illness are most likely to present with significant neurological
symptoms- from delirium, hallucinations, poor muscle control and unsteady gait, difficulty with
speaking or unclear speech to seizures or coma. These symptoms may be readily confused with
head trauma, epilepsy or drug overdose. Mortality is high and if a child survives heat stroke,
their risk for recurrence of heat illness is increased.38
As the body heats, it is susceptible to absorbing more chemicals. PFAS have been shown to be
absorbable via the skin.39
Natural grass Adjacent plastic Plastic turf; plant infill Same plastic field;
84F ambient air turf (GeoFill)109F ambient air different color
39 Ragnarsdóttir, O, Abou-Elwafa Abdallah, M, Harrad, S (June 2024). “Dermal bioavailability of
perfluoroalkyl substances using in vitro 3D human skin equivalent models.” Environment International;
188; 108772.b https://www.sciencedirect.com/science/article/pii/S0160412024003581?via=ihub
38 UpToDate (2023). “Heat Stroke in Children.” Online subscription based reference for health care
providers. https://www.uptodate.com/contents/heat-stroke-in-children
Plastic turf with crumb rubber infill
105F ambient temperature
The Lawrence Berkeley National Laboratory released a report in April 2024
finding that the greenhouse emissions from plastics are four times those emitted
by the aviation industry.40
40 Nihan, K, Khanna, N, Shah, N (Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence
Berkeley National Laboratory. https://energyanalysis.lbl.gov/publications/climate-impact-primary-plastic
Greenhouse Gas Emissions:
Synthetic turf is not eligible for exemptions under the California Environmental Quality Act
CEQA), for various reasons, including multiple and cumulative effects and greenhouse gas
emissions.
Cal. Code Regs. tit. 14 § 15064.4 (amendments effective 28 Dec 2018):
A good-faith effort, based to the extent possible on scientific and factual date, to describe, to:
1) Quantify greenhouse gas emissions resulting from a project; and/or
2) Rely on a qualitative analysis or performance-based standards
public agencies shall not undertake actions concerning the proposed public project
that would have a significant adverse effect or limit the choice of alternatives or
mitigation measures, before completion of CEQA compliance.”
In determining the significance of a project’s greenhouse gas emissions, the lead
agency should focus its analysis on the reasonably foreseeable incremental contribution
of the project’s emissions to the effects of climate change. A project’s incremental
contribution may be cumulatively considerable even if it appears relatively small
compared to statewide, national or global emissions. The agency’s analysis should
consider a timeframe that is appropriate for the project. The agency’s analysis also
must reasonably reflect evolving scientific knowledge and state regulatory
schemes.” [emphasis added]
Public Resources Code sections 21155.2 and 21159.28,
environmental documents for certain residential and mixed use projects, and transit
priority projects, as defined in section 21155, that are consistent with the general use
designation, density, building intensity, and applicable policies specified for the project
area in an applicable sustainable communities strategy or alternative planning strategy
need not analyze global warming impacts resulting from cars and light duty trucks. A
lead agency should consider whether such projects may result in greenhouse gas
emissions resulting from other sources, however, consistent with these Guidelines.”
State Air Resources Board pursuant to Division 25.5
commencing with Section 38500) of the Health and Safety Code.
To maximize public health, environmental, and employment benefits, the lead agency
shall require measures that will reduce the emissions of greenhouse gas[s]es in the
project area and in the neighboring communities of the baseball park. Not less
than 50 percent of the greenhouse gas emissions reductions necessary to achieve
the requirements of this clause, excluding the greenhouse gas emissions from
residential uses of the project, shall be from local, direct greenhouse gas
emissions reduction measures that give consideration to criteria air pollutant and
toxic air contaminant emissions reductions, including, but not limited to, any of
the following:
I) Project design features or onsite reduction measures, or both design features
and onsite reduction measures.
II) Off-site reduction measures in the neighboring communities.”
Senate Bill No. 32 = CHAPTER 249. An act to add Section 38566 to the Health and Safety
Code, relating to greenhouse gas[s]es:41
SEC. 2. Section 38566 is added to the Health and Safety Code, to read:
38566. “In adopting rules and regulations to achieve the maximum technologically feasible and
cost-effective greenhouse gas emissions reductions authorized by this division, the state board
shall ensure that statewide greenhouse gas emissions are reduced to at least 40 percent below
the statewide greenhouse gas emissions limit no later than December 31, 2030.”
Synthetic turf off gasses methane and ethylene42in ever increasing amounts. Synthetic turf fields
create massive toxic heat islands:
Methane traps 90% more heat than carbon dioxide.43
Methane is 21 times more potent than carbon dioxide.
Land based plastics produce 2 times more methane and 76 times more ethylene than
plastics in waterways and oceans.41
GHG emissions of 527 tons of CO2e per ten-year use period per 7881m2 plastic field.44
Heat islands extend beyond the footprint of the field, impacting the surrounding
community; are visible from satellites in space.
Microplastics:
The staff report notes that the plastic turf carpet is nearly devoid of plastic blades on the soccer
field at Luchessi Park, now long past its “best by” date. The loss of microplastics from the
synthetic turf has created an enormous amount of pollution, equating to 32,000 to 48,000
pounds over the last 16 years. See HERE and HERE.
44 Magnusson, Simon, Mácsik, Josef (July 2017). “Analysis of Energy Use and Emissions of Greenhouse
Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf.” Resources,
Conservation and Recycling: (122), Pages 362-372. https://doi.org/10.1016/j.resconrec.2017.03.
43 Climate Reality Project (2020). “REPOWER AMERICA®: Methane Stinks: Why Natural Gas is Bad
News For The Planet.”
https://www.climaterealityproject.org/blog/methane-stinks-why-natural-gas-bad-news-planet?_ga=2.52526
049.897177029.1647384251-251106713.1647384251
42 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic
in the Environment.” PlosOne 13(8): e0200574.
https://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0200574&type=printable
41 California State Legislature (2016). “Senate Bill No. 32 = CHAPTER 249. An act to add Section 38566
to the Health and Safety Code, relating to greenhouse gas[s]es.”
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?search_phrase=4x8x16&bill_id=201520160SB
32
6
Drainage systems, with or without filters, nor straw wattles or catchment basins, will solve the
issues of micro-, meso-, or nanoplastics. These plastic fragments readily loft into the air and can
travel for miles and reloft over and over. The same applies to these plastic fragments in water,
carrying their toxic payloads with them.45
In addition to the CA Statewide Microplastics Strategy - Senate Bill No.1263 (Chapter 609,
2018),46 CA DTSC has announced its intent to add Microplastics to the Candidate Chemicals
List.47
Microplastics not only leach chemicals, including endocrine disrupting forever PFAS, they
adsorb other chemicals and bacteria, posing particular risk to the food chain. Even the best
BMPs (Best Management Practices) will capture only a small percentage of the microplastics
and virtually none of the nanoplastics, PFAS and other toxic chemicals from synthetic turf.
Drainage systems are not expensive granulated activated carbon (GAC) filters.
47 Safer Consumer Product Program (2023). “Proposed Addition to the Candidate Chemicals List:
Microplastics.” California Department of Toxic Substances Control.
https://dtsc.ca.gov/scp/candidate-chemical-list_microplastics/
46 Senate Bill No. 1263 (2018). “CHAPTER 609: An act to add Chapter 3.2 (commencing with Section
35635) to Division 26.5 of the Public Resources Code, relating to pollution. State of California.
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1263
45 Lambert, S, Vercauteren, M, Catarino, AI et al (15 June 20240. “Aerosolization of micro- and
nanoplastics via sea spray: Investigating the role of polymer type, size, and concentration, and potential
implications for human exposure.” Environmental Pollution; (351), 124105
https://www.sciencedirect.com/science/article/abs/pii/S0269749124008194
In humans, micro- and nano-plastics have been found in:
Heart48
Liver and spleen49
Lungs50
Blood51
Placenta (maternal and fetal sides)52
Newborn and adult feces53
Bone marrow54
Breastmilk55
Bone marrow56
56 Guo, X, Wang, L, Wang, X et al (15 Sep 2024). “Discovery and analysis of microplastics in human bone
marrow.” Journal of Hazardous Materials; (477).
https://www.sciencedirect.com/science/article/abs/pii/S0304389424018454
55 Ragusa, A., Notarstefano, V., Svelato, A.. 2022. “Raman Microspectroscopy Detection and
Characterisation of Microplastics in Human Breastmilk.” Polymers (Basel); 14(13): 2700.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9269371/
54 Guo, X, Wang, L, Wang, X et al (15 Sep 2024). “Discovery and analysis of microplastics in human bone
marrow.” Journal of Hazardous Materials; (477).
https://www.sciencedirect.com/science/article/abs/pii/S0304389424018454
53 Staff writer (22 Sep 2021). “Infants have more microplastics in their feces than adults, study finds
Occurrence of Polyethylene Terephthalate and Polycarbonate Microplastics in Infant and Adult Feces.”
Environmental Science & Technology Letters.
https://www.acs.org/pressroom/newsreleases/2021/september/infants-have-more-microplastics-in-their-fe
ces-than-adults-study-finds.html
52Ragusa, A., Svelato, A.,, Santacroce, C. et al. (202). “Plasticenta: First Evidence of Microplastics in
Human Placenta.” Environment International: 146,106274.
https://www.sciencedirect.com/science/article/pii/S0160412020322297
51 Leslie, H.A., van Velzen, M.J.M., Brandsma, S.H.. 2022. “Discovery and Quantification of Plastic
Particle Pollution in Human Blood.” Environment International: 163,107199.
https://www.sciencedirect.com/science/article/pii/S0160412022001258
50 Jenner, L.C., Rotchell, J.M., Bennett, R.T. et al. 2022. “Detection of Microplastics in Human Lung
Tissue Using FTIR Spectroscopy.” Science of The Total Environment: 831,154907.
https://www.sciencedirect.com/science/article/pii/S0048969722020009?via%3Dihub
49 Urban, R.M., Jacobs, J.J., Tomlinson, M.J. et al. 2000. “Dissemination of Wear Particles to the Liver,
Spleen, and Abdominal Lymph Nodes of Patients with Hip or Knee Replacement.” Journal of Bone &
Joint Surgery: 82(4), 457.
https://journals.lww.com/jbjsjournal/Abstract/2000/04000/Dissemination_of_Wear_Particles_to_the_Liver,.
2.aspx
48 Lett, Z., Hall, A., Skidm, S.. 2021. “Environmental Microplastic and Nanoplastic: Exposure Routes and
Effects on Coagulation and the Cardiovascular System.” Environmental Pollution: 291, 118190.
https://www.sciencedirect.com/science/article/abs/pii/S0269749121017723?via%3Dihub
Breastmilk57
Brain58
Penis,59 Testes and semen60
Kidney61
Uterus62
Microplastic synthetic turf blades have been found in Lake Tahoe (personal email
communications with researchers at Tahoe Environmental Research Center (TERC)) and the
ocean. In 2021, researchers found that synthetic turf fields in Toronto contribute the 2nd highest
amount of microplastics to the environment with only litter contributing a higher amount.63 This
makes synthetic turf a major source of toxic chemicals and microplastic pollution that cannot go
unaddressed. Lake Tahoe researchers found high levels of polyethylene and polypropylene in
the lake and “…recorded plastics concentrations more than three times higher than those
sampled using a similar method in the North Atlantic subtropical gyre.”
Published on 29 June 2023, research by the University of Barcelona64 found:
AT [artificial turf] fibers - composed mainly of polyethylene and polypropylene - can
constitute over 15% of the mesoplastics and macroplastics content, suggesting that AT
fibers may contribute significantly to plastic pollution. Up to 20,000 fibers a day flowed
down through the river, and up to 213,200 fibers per km2 were found floating on the sea
64 De Haan, William P., Quintana, Rocio, Vilas, César, Cózar, Andrés et al. 2023. “The dark side of
artificial greening: Plastic turfs as widespread pollutants of aquatic environments.” Environmental
Pollution; 334, 122094.
https://www.sciencedirect.com/science/article/pii/S0269749123010965?via%3Dihub
63 Zhu, X, Hoffman, M, Rochman, C (1 Feb 2024). A City-Wide Emissions Inventory of Plastic Pollution.
Environ. Sci. Technol; 58, 7, 3375–3385. https://doi.org/10.1021/acs.est.3c04348
62 Xu, H, Dong, C, Yu, Z et al (27 Jul 2024). “First identification of microplastics in human uterine fibroids
and myometrium.” Environmental Pollution. https://pubmed.ncbi.nlm.nih.gov/39074687/
61 de Oliveira, RB, Pelepenko, LE, Masaro, DA et al (Sep 2024). “Effects of microplastics on the kidneys:
a narrative review.” Kidney Intl: (106)3, p400-407.
https://www.kidney-international.org/article/S0085-2538(24)00404-6/abstract
60 Zhao, Q., Zhu, L., Weng, J. et al. 2023. “Detection and Characterization of Microplastics in the
Human Testis and Semen, Short Communication.” Science of The Total Environment: 877, 162713.
https://www.sciencedirect.com/science/article/abs/pii/S0048969723013293#:~:text=Microplastics%20in%
20the%20testis%20were%20composed%20of%20polystyrene,fragment%20was%20the%20main%20sha
pe%20the%20in%20testi
59 Codrington, J, Aponte Varnum, A, Hildebrand, L et al (19 June 2024). “Detection of microplastics in the
human penis.” Intl J Impotence Research. https://pubmed.ncbi.nlm.nih.gov/38890513/
58 Prüst, M., Meijer, J., Westerink, R.H.S.. 2020. “The Plastic Brain: Neurotoxicity of Micro- and
Nanoplastics.” Part Fibre Toxicol;17(1):24.
https://pubmed.ncbi.nlm.nih.gov/32513186/#:~:text=Upon%20uptake%2C%20micro-%20and%20nanopla
stics%20can%20reach%20the,brain%20to%20exert%20a%20range%20of%20neurotoxic%20effects
57 Ragusa, A., Notarstefano, V., Svelato, A.. 2022. “Raman Microspectroscopy Detection and
Characterisation of Microplastics in Human Breastmilk.” Polymers (Basel); 14(13): 2700.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9269371/
surface of nearshore areas. AT, apart from impacting on urban biodiversity, urban runoff,
heat island formation, and hazardous chemical leaching, is a major source of plastic
pollution to natural aquatic environments.”
This research lead to the California Coastal Commission's decision to not allow synthetic turf
use in the coastal zone at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not
superior to natural grass and is not sustainable.
Section 21080.5(d)(2)(A) of CEQA prohibits the Commission from approving a proposed
development if there are feasible alternatives or feasible mitigation measures available
that would substantially lessen any significant adverse effect which the activity may have
on the environment. For the reasons discussed in this report, the Commission has
conditioned the NOID to require design and implementation of Final Revised Project
Plans that do not include the installation of artificial turf.”65
Seabin Foundation’s Ocean Health Lab reported that within the first four months of 2024, it
recorded 194 artificial plants and 938 artificial grass fibres (> 5mm) captured in Seabins
around Sydney Harbour. Shockingly, this represents only 10.27% of what Seabins are capturing
daily, and this would equate to approximately 1,992 artificial plants and 9,633 artificial grass
fibres captured in all the 32 Seabins in four months, which again, is only a sample of what’s
entering the Harbour. This suggests the amount of artificial plants and grass polluting our
waterways and the Ocean is much, much higher.”66
Infill loss constitutes 1 to 5 tonnes per year, per a 2019 presentation conducted by The
Synthetic Turf Council (image has been deleted from internet).
66 Mylius, K (11 July 2024). “Keep the Fake Plants and Turf Out of the Surf: A call to action to reduce the
use of artificial grass and plants in our cities, preserving natural greenery and its benefits, and cleaning
the Ocean.” SeaBin Foundation, Australia.
https://seabinfoundation.org/keep-the-fake-plants-and-turf-out-of-the-surf/
65 California Coastal Commission (13 Dec 2023). “Notice of Impending Development UCS-NOID-0002-23
Baseball Stadium Turf).”
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf
Tyre granulate on the loose; How much escapes the turf? 2023
Loss of tire crumb based on a 7526m2 regulation sized field (81,008.2 ft2) is significant, even
with the best BPMs in place. Tire crumb loss via surface water can range up to 281kg/year,
even with drain filters, and represents a small portion of the infill lost annually.
Impervious Surface:
Synthetic turf is an impervious, or impermeable, surface, despite what the industry tells you.
The US EPA and the State of California are clear on this issue:67
areas such as gravel roads...that will be compacted through design or use to reduce
their impermeability.” It further has defined impervious surfaces as…[a]ny surface that
prevents or significantly impedes the infiltration of water into the underlying soil. This can
include but is not limited to: roads, driveways, parking areas and other areas created
using non porous material; buildings, rooftops, structures, artificial turf and compacted
gravel or soil.”
Compaction, as well as the impervious plastic surface, result in increased runoff. Despite
synthetic turf industry claims, laboratory testing is not the same as reality. Synthetic turf is
unable to handle the amount of rain that comes with an atmospheric river or bomb cyclone.
With 12 atmospheric rivers since December 2022 (Scripps Institute of Oceanography, UC San
Diego reports 29), predictions of a coming El Niño, increasing frequency and severity of
atmospheric events overall, consideration of synthetic turf is antithetical to environmental
responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years
on average.
Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until
runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into
stormwater drains and directly to local waterbodies. As impervious surfaces increase,
stormwater runoff increases in quantity, speed, temperature, and pollutant load. When
impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and
continues to increase until, at 100% impervious surface coverage, runoff is five times
that of a forested watershed. Excessive stormwater runoff also increases the potential
for flooding.”68
Luchessi Park has a large pond and is adjacent to Lynch Creek, which runs to the Petaluma
River and out to the bay.
Plastic turf does not save water:
Synthetic turf requires approximately 989 gallons of water to produce 1 square meter of turf-
estimated69 to be the equivalent of watering a square meter of natural grass for 18 years.
Additional water is required for cooling to a safe temperature for playing as well as for cleaning
pollution, bodily fluids (like blood and vomit), animal waste, mold, bacteria and more from plastic
turf and is often a condition of warranty.
69 Waterwise UK. “How to save water: Artificial Grass’s Footprint.”
https://www.waterwise.org.uk/save-water/
68 US EPA (2020). “EnviroAtlas: Fact Sheet, Percent Impervious Area.”
https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/ESN/PercentImperviousArea.pdf
67 US EPA, MS4 General Permit Appendix A, Definitions, Abbreviations and Acronyms,
https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-a-2016-ma-sms4-gp.pdf
Research has shown that synthetic turf requires more water than drought tolerant Bermuda
varieties in an arid environment in order to bring the surface temperature down to a level
comparable to natural grass for safe play.
While proper irrigation or water-cannon systems can lower the temperatures for 20+ minutes,
plastic fields rapidly return to the high temperatures.
480,000 L of water at 25°C are required to decrease the surface temperature
from 60°C [140°F] to 30°C [86°F]...the amount of water required to maintain [artificial
turf] temperatures at levels comparable to irrigated [natural turf] over a 24-h period
exceed the water requirements of Bermuda grass in the same environment.”70
A report on water use on synthetic turf found that 2 water cannons spraying water from the
center of the field moving towards each end simultaneously was the most effective, as one
cannon only resulted in the first end drying before the second was sprayed. In September and
October, 12,000 gallons of water were required each time the field needed to be cooled.71
Irrigation is required to clean synthetic turf. Warranties generally call for synthetic pesticides to
control weed growth through and on the surface of the plastic carpeting. Potable water is
required to clean the plastic to avoid the color bleaching that occurs with higher salt and mineral
content of reclaimed water. Additionally, cleaning of synthetic turf requires the use of toxic
71 Princeton University. Bedford Stadium blog. https://goprincetontigers.com/facilities/bedford-field/11
70 Kanaan, A, Sevostianova, E, Leinauer, B, Sevotianov, I (2020). “Water Requirements for Cooling
Artificial Turf.” Up loaded copy: https://doi.org/10.1061/(ASCE)IR.1943-4774.0001506
chemicals, which will be added to the toxic run-off that leaches from the plastic to soil, air and
water.
Potential for erosion; toxic runoff:
Synthetic turf does not save water and will generate 27,000 gallons of toxic runoff per 1 acre of
plastic for every one inch of rainfall.72 Toxic runoff from the two synthetic fields, (93,116 ft2 +
37,450 ft2 as measured on google earth) totaling 3 acres…that is 81,000 gallons of toxic runoff
per one inch of rainfall. Petaluma’s annual rainfall averages 25.6 inches,73 constituting
2,073,600 gallons of toxic runoff per year from these two plastic grass carpets alone.
Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until
runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into
stormwater drains and directly to local water bodies. As impervious surfaces increase,
stormwater runoff increases in quantity, speed, temperature, and pollutant load. When
impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and
continues to increase until, at 100% impervious surface coverage, runoff is five times
that of a forested watershed. Excessive stormwater runoff also increases the potential
for flooding.”64
From the foremost researcher on PFAS in consumer products, professor emeritus Dr. Graham
Peaslee, University of Notre Dame:
PFAS is probably the worst environmental pollutant that the United States has
ever faced. It makes all the rest” — including PCBs and asbestos — “pale in
comparison to what the cost of this cleanup will be…and it will affect more people
than all known pollutants combined.” Dr. Graham Peaslee, University of Notre
Dame, leading expert on PFAS in consumer products.
73 Average Annual Precipitation for Cities in California (2025). Current Results: Science and Weather
Facts
https://www.currentresults.com/Weather/California/average-yearly-city-precipitation.php
72 Cotrone, V (undated). “The Role of Trees and Forests in Healthy Watersheds: Managing stormwater,
reducing flooding, and improving water quality.” Penn State Extension.
https://extension.psu.edu/the-role-of-trees-and-forests-in-healthy-watersheds
How much PFAS is Petaluma allowing to run off of synthetic turf?74
Scripps Institute of Oceanography, University of California San Diego reported 46 total
atmospheric rivers along the U.S. West Coast, causing disastrous flooding and loss of property
and life during the 2022 to 2023 rainy season.75 With increasing frequency and severity of
atmospheric events overall, consideration of synthetic turf is antithetical to environmental
responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years
on average.
There is a ready solution for a permeable surface: Natural Grass. Organically/regeneratively
managed will make it non-toxic and allow recharging of the water table, increase carbon
sequestration and remove toxic exposure to people, pets, and planet from the playing fields.
75 Leinen, M (2023). “Scripps Oceanography Annual Impact Report.”
https://scripps.ucsd.edu/annual-report-2023
74 Peaslee, GF (27 Aug 2024), Slide deck presentation at DTSC: “Chemicals of Concern in Syntheit Turf.”
Peaslee, GF. CA DTSC Aug 2024
Plant and mineral based infills:
Plant and mineral based infills have not been proven safe76 and does not mitigate the chemicals
leaching from the plastic carpets and draining into surface and groundwater, contaminating
drinking water and the bay.
The proposed olive pit infill may be sourced from Portugal or another country. Hellas
Construction,77 a TenCate Company,78 Olive orchards are prone to disease and extensive use of
pesticides is not uncommon, even in the US.79.80 All are mixed with silica sand (on CA
Proposition 65 list as a known carcinogen)81 and in some cases with zeolite.82
Zeolite has been known to cake due to rain or watering and caking between the blades of the
plastic carpet, necessitating replacement of the entire field. Like silica sand, and plant based
infill, it poses a risk due to inhalation. Zeolite inhalation has been linked to development of
respiratory disease and potentially mesothelioma.83,84
84 Memorial Sloan Kettering Cancer Center (2023). “Zeolite: Purported Benefits, Side Effects & More
https://www.mskcc.org/cancer-care/integrative-medicine/herbs/zeolite
83 Parents Coalition of Montgomery County, Maryland (5 Oct 2018). “Kitty Litter/Zeolite Dust Cloud at the
New Whitman HS Artificial Turf Football Field. Play Ball, But Don't Breathe.” Blog post; Accessed 1
Feb 2025. Zeolite, Montgomery County Maryland
82 Sick, S et al (19 Dec 2022). “An artificial turf infill comprising olive pit fragments and microporous zeolite
particles.” Patent application; Polytex Sportbelage Produktions-GmbH. Accessed 1 Feb 2025.
https://patents.justia.com/patent/20240084523
81 State of California, Environmental Protection Agency (3 Jan 2025). “Safe Drinking Water and Toxic
Enforcement Act of 1986: Proposition 65 List of Carcinogens or Reproductive Toxicants.”
https://oehha.ca.gov/sites/default/files/media/downloads/proposition-65//p65chemicalslist.pdf
80 Statewide Integrated Pest Management Program (undated). “Agriculture: Olive Pest Management
Guidelines: Herbicide Treatment Table.” University of California Agriculture and Natural Resources.
Accessed 1 Feb 2025.
https://ipm.ucanr.edu/agriculture/olive/herbicide-treatment-table/#gsc.tab=0
79 Statewide Integrated Pest Management Program (undated). “Agriculture: Pest Management Guidelines
Olive.” University of California Agriculture and Natural Resources. Accessed 1 Feb 2025.
https://ipm.ucanr.edu/agriculture/olive/#gsc.tab=0
78 TenCate. Announces aquistion of Hellas Construction (2022).
https://tencategrass.com/companies/hellas-construction/
77 Panjiva. S&P Global Marketing Research. Hellas Construction receipt of olive pits from Portugal.
Accessed 1 Feb 2025
https://panjiva.com/shipment_search/results?user_term=1&prefilter=none&type=us_imports&q=Hellas
Construction&commit=Search
76 Massey, R, Onasch, J, Pollard, L (2019). “Athletic Playing Fields, Choosing Safer Options.” Toxic Use
Reduction Institute (TURI), University of Massachusetts, Lowell,.
https://www.turi.org/publications/athletic-playing-fields-choosing-safer-options-for-health-and-the-environ
ment/
Plant based infill requires approximately 3200 gallons of potable water per 80,000 square feet of
plastic playing field every 3 to 4 days on average. Potable water is required as reused water,
which has a higher salt content, damages the plastic playing field, breaking it down into
microplastics even more rapidly.
Plant based infill adds an additional 70% to the 527 tons of carbon dioxide equivalents off
gassed every 10 years from a single regulation sized playing field.43
Injuries:
Independent peer-reviewed research consistently shows significantly increased non-contact
lower extremity injuries85 and concussions,86 particularly for children87- playing on synthetic turf
is a contributing factor.
The available body of literature suggests a higher rate of foot and ankle injuries on
artificial turf, both old-generation and new-generation turf, compared with natural grass.
High-quality studies also suggest that the rates of knee injuries and hip injuries are
similar between playing surfaces, although elite-level football athletes may be more
predisposed to knee injuries on artificial turf compared with natural grass. Only a few
articles in the literature reported a higher overall injury rate on natural grass
compared with artificial turf, and all of these studies received financial support
from the artificial turf industry.”74
Another reminder that independent, peer-reviewed research matters.
87 Villanueva, N, Chun, I, Fujiwara, A et al (Jan 2024). “Impact Deceleration Differences on Natural
Grass Versus Synthetic Turf High School Football Fields.” Hawaii Journal of Health; 82 (1) 4-10.
http://hawaiijournalhealth.org/past_issues/HJHSW_Jan24.pdf
86 The Concussion Legacy Foundation. 2015. “White Paper: The Role of Synthetic Turf in Concussion.”
Accessed 1 Feb 2025.
https://concussionfoundation.org/sites/default/files/Learning%20Center/The%20Role%20of%20Synthetic
20Turf%20in%20Concussion_0.pdf
85 Gould, Heath P., Lostetter, Stephen J., Samuelson, Eric R., Guyton, Gregory P.. 2022. “Lower
Extremity Injury Rates on Artificial Turf Versus Natural Grass Playing Surfaces: A Systematic Review.”
Am J Sports Med. 2023 May: 51(6):1615-1621. Epub 2022 May 20.
doi: 10.1177/03635465211069562
Exposure to Methicillin-resistant Staphylococcus aureus (MRSA)88 and other bacteria89 are a
potentially life threatening consequence of dermal abrasions, known as turf burns, due to friction
on synthetic turf. Inhalation and ingestion are additional exposure pathways. Non contact lower
body injuries90 are significantly higher on synthetic turf, as are concussions and heat stroke.91
92
92 Turfgrass Producers International (2019). “Incidence of Knee Injuries on Artificial Turf Versus Natural
Grass in National Collegiate Athletic Association American Football: 2004-2005 Through 2013-2014
Seasons.” Incidence of Knee Injuries on Artificial Turf Versus Natural.
https://turfgrasssod.org/wp-content/uploads/2023/10/TPI-NCAA-2013-2014-Case-Study-7.12.pdf
91 Abraham, J. (2019). “Heat risks associated with synthetic athletic fields.” International Journal of
Hyperthermia; 36(1), 515–516.
https://doi.org/10.1080/02656736.2019.1605096
90 Louhgran, GJ, Vulpis, CT, Murphy, JP (17 Apr 2019). “Incidence of Knee Injuries on Artificial Turf
Versus Natural Grass in National Collegiate Athletic Association American Football: 2004-2005 Through
2013-2014 Seasons.” Am J Sports Med; 47(6), 1294-1301.
https://turfgrasssod.org/wp-content/uploads/2023/10/TPI-NCAA-2013-2014-Case-Study-7.12.pdf
89 Valeriani, F, Margarucci, LM, Gianfranceschi, G et al. (Aug 2019). “Artificial-turf surfaces for
sport and recreational activities: microbiota analysis and 16S sequencing signature of synthetic
vs natural soccer fields.” Heliyon; 5(8): e02334.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6728760/
88 US EPA (6 Aug 2019). “U.S. Federal Research Action Plan (FRAP) on Recycled Tire Crumb Rubber
Used on Synthetic Turf Playing Fields and Playgrounds. Final Report Part 1 – Tire Crumb
CharacterizationEPA Tools and Resources Webinar.”
https://www.epa.gov/sites/default/files/2019-08/documents/tc_public_webinar_-_august_6_2019
pdf slide 20
315,000 to 850,000 concussions every year occur among high school athletes.
Repeated concussions increase risk of Chronic Traumatic Encephalopathy (CTE)/
The Concussion Legacy Foundation reported that repetitive brain trauma is associated
with CTE and has been found in 17 year olds. 41.4% of athletes under age 30 show
signs of CTE.93
In high school American football players, concussions occur when head impacts
approach 95 g.
For youth American football players aged 9-14; 62.4 ± 29.7 g was the threshold for
concussions.
Research published Jan 2024 showed significantly greater impact deceleration on
synthetic turf compared to natural grass surfaces, showing greater potential for
concussions on synthetic fields.94
Newer synthetic turf fields require a greater fall distance to attenuate head to surface
impact, which again, puts children at higher risk.
Turf burns occur on synthetic turf because it does not pull away as natural grass does with
changes in motion and direction.
A lawsuit against Stanford University and the City of Palo Alto were sued on 30 Nov. 2024 for an
injury sustained on a synthetic field the University leases to the city of $1/year.
Professional players across multiple sports are calling for a return to natural grass.95 Elite
soccer players will not play on plastic turf and the National Women’s Soccer League sued in
order to play on natural grass.
95 Online petition: FlipTheTurf:
https://www.change.org/p/fliptheturf-it-s-time-to-swap-nfl-stadium-turf-for-real-grass
94 Villanueva, NC, Chun, IKH, Fujiwara, AS et al (Jan 2024). “Impact Deceleration Differences on Natural
Grass versus Synthetic Turf High School Football Fields.” Hawai‘i Journal of Health; (83)1, pp4-9.
http://hawaiijournalhealth.org/past_issues/HJHSW_Jan24.pdf
93 Ober, M (28 Aug 2023). “41% of Young Athletes Show Signs of CTE.” Neuroscience News; Boston
University. https://neurosciencenews.com/cte-young-athletes-23847/
Hours of play:
As with so many claims made by the synthetic turf industry, 1,000 to 3,000 hours of play is
completely unsubstantiated and is yet another myth they have perpetuated for years. Claims are
not proof.
In a 2014 article in Forbes Magazine titled How Taxpayers Get Fooled On The Cost Of An
Artificial Turf Field96 by Mike Ozanian, dubbed “the traffic cop at the intersection of money and
sports”:
Towards the bottom of the chart the number of hours the artificial turf field is used is
doubled to twice the use of the natural grass field, thus based on "cost per hours of use"
projections the artificial field is now cheaper. This type of math reminds me of the guy
who went to a sale at a store determined to buy enough items on sale so that his he
would "save" enough to pay for everything.”
A reduction in hours of use will be increasingly impacted by:
Climate change- extreme heat and atmospheric river events
96 Ozanian, M ( 2014). “How Taxpayers Get Fooled On The Cost Of An Artificial Turf Field.” Forbes
Magazine.
https://www.forbes.com/sites/mikeozanian/2014/09/28/how-taxpayers-get-fooled-on-the-cost-of-
an-artificial-turf-field/
AB 1653- Intercollegiate athletic programs emergency action plans: heat illness:
guidelines97
CIF Rule98 - California Interscholastic Federation Rule on air quality/particulate matter
NOT recyclable:
Less than 6% of plastics are recycled.99 Made of mixed plastics, synthetic turf is not recyclable,
not sustainable and is a linear, not a circular product, and does not meet any definition of
sustainability. The synthetic turf industry misrepresents its products when they make claims
related to sustainability and environmentally friendliness. It is not enough to use the vernacular
of the day.
Circular products100 are “…those products that have reduced or completely no need for virgin
resources and are designed with the end of their life in mind.”
The United Nations defines sustainable development101 as “development that meets the needs
of the present without compromising the ability of future generations to meet their own needs.”
The UCLA Sustainability Committee102 notes: “In simplest terms, sustainability is about our
children and our grandchildren, and the world we will leave them”.
The Rutgers Center for Sustainable Materials103 definition:
Sustainable materials are materials used throughout our consumer and industrial
economy that can be produced in required volumes without depleting non-renewable
resources and without disrupting the established steady-state equilibrium of the
environment and key natural resource systems.”
103 Rutgers University. “What are Sustainable Materials?” Department of Materials Science and
Engineering, Center for Sustainable Materials. Accessed 26 Jan 2025.
https://mse.rutgers.edu/center-sustainable-materials
102 UCLA Sustainability Committe, quoting UN World Commission on Environment and Development
https://www.sustain.ucla.edu/what-is-sustainability/
101 United Nations (2024). “Sustainable Development Agenda: What is sustainable development?”
https://www.un.org/sustainabledevelopment/development-agenda/#1b1981a30bdd8fde2
100 “What is a circular product?” Circular Tayside, United Kingdom.
https://circulartayside.co.uk/what-is-a-circular-product-and-business-model/
99 Dell, J, Enck, J (May 2022). “The Real Truth about the US Plastic Recycling Rate.” Beyond Plastics.
https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/62b2238152acae761414d698/1655
841666913/The-Real-Truth-about-the-US-Plastic-Recycling-Rate-2021-Facts-and-Figures-_5-4-22.pdf
98 California Interscholastic Federation (Oct 2023). “CIF Sports Medicine Advisory Committee
Statement on Air Quality and Sport Participation. https://www.cifstate.org/sports-medicine/aqi
97 State of California (8 Oct 2023). “Assembly Bill No. 1653; CHAPTER 589. An act to amend Section
35179.4 of, and to add Section 35179.8 to, the Education Code, relating to interscholastic athletics.”
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1653
The United Nations defines sustainable development104 as “development that meets the needs
of the present without compromising the ability of future generations to meet their own needs.”
Unnder SB54-Allen (2022),105 “recycle” or “recycling” does not include any of the following:
Combustion
Incineration
Energy generation
Other forms of disposal
Fuel production (except for anaerobic digestion of source separated organic materials)
To be considered recycled, covered material shall be sent to a responsible end market.
The reality is, many landfills will not accept the massive amounts of plastic waste synthetic turf
fields consist of. Removal of each regulation-sized field would result in approximately 200 rolls
weighing 2,000 pounds each, then transported 18 rolls per flatbed semi-truck to their disposal
site. They are most often dumped on agricultural land or stored in warehouses and listed for
resale to unsuspecting customers on Craigslist, Facebook Marketplace and other internet
outlets. This is not recycling, but rather kicking the can down the road, leaving future
generations to contend with the multiple long term human and environmental health effects from
massive quantities of plastic waste.
We cannot stress strongly enough that there is NO independently verifiable “recycling” of
synthetic turf anywhere. Again, claims are claims and do not constitute proof.
San Martin, CA New Jersey Warehouse Pescadero, CA
105 Senate Bill No. 54: CHAPTER 75: An act to amend Section 41821.5 of, to add Chapter 3 (commencing
with Section 42040) to Part 3 of Division 30 of, and to repeal Section 42064 of, the Public Resources
Code, relating to solid waste.
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB54
104 United Nations (2024). “Sustainable Development Agenda: What is sustainable development?”
https://www.un.org/sustainabledevelopment/development-agenda/#1b1981a30bdd8fde2
Sacramento, CA Sherwood, OR
Lincoln, CA- slicing and dicing is NOT recycling.
Where is the PROOF of recycling?
TenCate/GeoSurfaces “recycling” facility near Baton Rouge, LA
A lobbyist for The Synthetic Turf Council gave testimony in the California Senate Finance and
Governance Committee on 12 July 2023 stating:106
One thing we don't want to do is to set a [PFAS] limit that's so low that we can't recycle
the products because you're going to have environment--I mean, PFAS is
everywhere--so you're going to have environmental PFAS that's out there. We want to
still be able to recycle products. We don't want to have a situation where we're no longer
be able and it has to go to the waste stream instead of be recycled in some way.”
The same lobbyist testified in the California Senate Environmental Quality Committee on 19
June 2024, stating that the largest carpet recycler in Los Angeles cannot recycle synthetic
turf.107
The Trex Company, in a 2022 email, stated they will not accept synthetic turf for use in
manufacturing of their composite wood/plastic fencing and decking due to the environmental
contamination of the fields.108 Trex is also not recyclable and old fencing and decks fill
warehouses in Los Angeles, per a regional sales representative at an in person meeting in
2022.
One “recycler” with grandiose claims that it would be able to “recycle” 60k tons of synthetic turf
per year (3,000 regulation sized 80k square feet fields; 40,000 pounds for carpet and backing;
400,000 pounds of infill), obtained tax incentives in both PA and CA. They have failed to open a
108 Trex Company (2022). Email communication re: use of synthetic turf as component in recycled
composite fencing, decking.
https://drive.google.com/file/d/1n-TIJz9bhhI3URi-4lK8T9emHf8peH3L/view?usp=drivesdk
107 Herner, G (19 June 2024). Testimony by lobbyist for The Synthetic Turf Council to California Senate
Environmental Quality Committee.
https://www.senate.ca.gov/media-archive?time[media-element-17637]=10986.452405744669
106 Herner, G (12 July 2023), testimony by lobbyist for The Synthetic Turf CouncilCalifornia Senate
Finance and Governance Committee.
https://digitaldemocracy.calmatters.org/hearings/256955?t=598&f=ce6036336de24ded1622306
45d70036f
plant in either state, and have never recycled a single old field into a new field in their home
country of Denmark and have now closed the Danish “recycling” plant.109 With an estimated
30,000 synthetic turf fields in existence in the U.S., it would take 10 years to recycle the current
fields with no new fields brought into the market.
Two other companies, TenCate and FieldTurf, claim to be shipping chopped up old carpets to
Cyclyx in Houston for further processing, then to ExxonMobil in Baytown,Texas for “advanced
chemical recycling,” where the plant is fraught with millions of dollars in fines for violations.
These claims have been debunked by investigative reporters.110,111 TenCate further claims to
have a new “recycling” plant in the cancer alley112 area near Baton Rouge, LA.113 FieldTurf has
also made claims of a “recycling” plant in the Wilkes-Barre, PA area. These, again, are claims.
The industry has refused to allow investigative reporters or anyone other than decision makers
to visit their sites, and does not allow transparency by following the complete trail behind the
claims. There is no independently verifiable proof that any plastic fields have been processed or
recycled” anywhere.
When “mechanically” recycled (chopped up, essentially) for use in other products, the toxic and
carcinogenic effects are added to the new product, along with additional toxic and carcinogenic
chemicals. Only about 1% of the old material is used and the process requires more virgin
plastic and additional PFAS and other toxic chemicals. Downcycling plastics into new products
creates lesser quality products that are not recyclable.
Research published in 2023 on a single northern Scotland recycling facility that accepts 22,680
tonnes of mixed plastic waste annually showed mechanically recycling plastics resulted in the
release of up to 3,000,000 pounds of microplastics into the environment in a single year. The
implications of this research indicate “…as much as 400,000 tons [800,000,000 pounds] per
year in the United States alone, or the equivalent of about 29,000 dump trucks of
microplastics.”114
114 Bruggers, J (23 May 2023). “Who Said Recycling Was Green? It Makes Microplastics By the Ton
113 Duchmann, H (June 2023). “Advance notices filed for new Exxon-affiliated recycling facility.” 10/12
Industry Report (news, data, analysis and insight into the petrochemical and oil and gas industries in
south Louisiana)
https://www.1012industryreport.com/workforce/advance-notices-filed-for-new-exxon-affiliated-recycling-facility/
112 Staff writer (25 Jan 2024). “US: Louisiana’s ‘Cancer Alley’ Dire Health Crisis From Government Failure
to Rein in Fossil Fuels.” Human Rights Watch
https://www.hrw.org/news/2024/01/25/us-louisianas-cancer-alley
111 Song, L (20 June 2024). “Selling a Mirage.” Propublica.
https://www.propublica.org/article/delusion-advanced-chemical-plastic-recycling-pyrolysis
110 Bruggers, J (24 Aug 2024). “Houston’s Plastic Waste, Waiting More Than a Year for ‘Advanced’
Recycling, Piles up at a Business Failed Three Times by Fire Marshal.” Inside Climate News,
https://insideclimatenews.org/news/24082024/houston-advanced-recycling-plastic-waste-piles-up/?utm_s
ource=InsideClimate+News&utm_campaign=cb698c57f4-EMAIL_CAMPAIGN_2024_08_24_01_01&utm_
medium=email&utm_term=0_29c928ffb5-cb698c57f4-331114526
109 Oldenkotte, G (7 Jan 2025).”Re-Match discontinues operations in Denmark.” SportsFieldInfo.
https://sportsfields.info/re-match-discontinues-operations-in-denmark/
When shipped out of state for “advanced chemical recycling” (banned in CA under SB54-Allen,
2022),115 cities, counties, boards of education, and the synthetic turf industry contribute to the
negative human and environmental health effects of Environmental and Social Justice (EJ/SJ)
communities. Landfilling and dumping used rolls also often occurs in EJ/SJ communities.
Fossil fuel-based petrochemical plastic grass carpets continue to leach their toxic contents for
the estimated 1,000 years it will take for them to fully degrade.116
Hidden costs associated with synthetic turf:
Annual GMax testing- ~$1,515. More frequently if it fails testing. A maximum result of
165 is the safety threshold advised by Sports Field Management Association, a
professional association with a core mission being safety of athletes of all ages and
abilities, from peewee to professional. 165 is also found in the Synthetic Turf Council
STC) Glossary of Terms and Guidelines for Synthetic Turf Performance (when were
Lucchesi’s 2 plastic fields last tested for hardness?)
Annual infill replenishment- 1.5 to 5 tons of chosen infill *plant based infill is generally 4.5
times more expensive than used tire crumb
New maintenance equipment
Maintenance agreement costs (required by FieldTurf warranty)
Increased water to cool plastic surface to playable temperature. *Plastic fields readily
reach 150ºF to 180ºF. A report found in September and October, 12,000 gallons of water were
required each time the field needed to be cooled (cooling effect only lasts approximately
20-50 minutes) Cleaning solvent. *
failure to follow maintenance requirements will nullify warranty. What is the
proposed solvent, amounts to be used, costs, associated risks to human and environmental health?
Pesticide for
weed eruption. Many recommended glyphosate. *weed eruption is common Projected
removal,
transportation and disposal costs *will most likely be hazardous waste landfills
once under regulation and with PFOA and PFOS being declared hazardous. Santa
Clara County staff reported a quote of $115k-$148K for a small field117; Fremont
Union High School District is still paying off $870+k for removal and recycling” of
6 fields in summer 2024; 6 more are planned.118 Plastic fields have needed replacement in
as little as 1 to 4 yrs., 118 Freemont
Union HS District AT removal, disposal 117 Santa
Clara County meeting packet 28 Jan 2025 116 Chamas,
A, Moon, H, Zheng, J (3 Feb 2020). “Degradation Rates of Plastics in the Environment.” ACS Sustainable
Chemistry & Engineering;(8)9.b https://pubs.
acs.org/doi/10.1021/acssuschemeng.9b06635 115 Lapsley,
RC (3 Nov 2022). Guest Commentary: “Advanced recycling is booming except in California. A new plastics
law is to blame.” CalMatters. https://calmatters.
org/commentary/2022/11/plastic-advanced-recycling-california-turf/ A study
finds one plastics recycling plant in the U.K. produces as much as 3 million pounds of microplastics a
year—and that’s with filtering.” Inside Climate News https://insideclimatenews.
org/news/16052023/recycling-plastic-microplastics-waste/
Ultimately, remediation of soil and water prior to installation of natural grass field and
synthetic turf comes under regulation and PFAS legislation
Liability for water quality violations; increased injuries/heat stroke (potential death) on
synthetic turf
Synthetic turf requires use of potable water, not recycled water - which would damage
the plastic fields due to higher salt content. Vast amounts of potable water are required
to clean the fields of human and animal waste and bacteria and cool the plastic surface
to a temperature safe for play
Shaw recommends 3200 gallons of water per 80,000 ft2 to hydrate GeoFill coconut
coir infill every 3 to 4 days119
https://www.shawsportsturf.com/geofill/
Social Equity:
Equity in sports does not mean exposing exposing people of color, vulnerable populations or to
environmental and/or social justice communities. Plastic turf does not increase equity.
We noticed, based on the most recent census data, that 42% of Petaluma’s population is
represented by people of color. 19.5% speak a language other than English in their home.
We seriously question the validity of the survey done by staff, which skews towards plastic turf
also noted was a discrepancy between field size as reported and measurements per google
earth):
In the Spanish language version, 91.7% respondents identified as parents of players,
8.3% players. 50% identified players as between ages 12-18, 41.7% ages 8-11, and
8.3% age 19 and over.”
How many responded to the Spanish version? Why did the survey not include questions
regarding:
Knowledge of toxic and carcinogenic exposures in synthetic turf?
Whether parents/caregivers would be willing to sign consents related to toxic exposures
and higher injury rates? Only emancipated or pregnant minors can give informed
consent.
Safety of organically/regeneratively maintained fields?
119 https://www.shawsportsturf.com/geofill/
Equity would be offering reduced fees or scholarships for those that cannot afford team sports;
ensuring equal open field play time as scheduled play time; ensuring that Petaluma residents
have more access to their own parks and playing fields, not organized team sports or teams
from other cities.
Equity is not exposing Environmental Justice and Social Justice (EJ/SJ) and vulnerable
populations to more heat islands, neurotoxic and cancer causing chemicals and higher fiscal
burden. These communities already bear a higher burden from health issues, access to health
care and information due to language and other social and cultural barriers.
120
Petaluma DESERVES natural grass fields!
Grass doesn’t waste water. People do!”
Dr. James Baird, UC Riverside Turfgrass Management Program
Grass fields actively sequester carbon dioxide and provide a cooling function that is especially
dramatic when compared to the heat generated by synthetic turf. Grass naturally filters toxins,
performs important eco-services for the soil beneath, and provides widely dispersed rainwater
infiltration allowing absorption and recharging of the water table. Additionally:121
Research suggests that grasses can accumulate and deposit carbon into the soil by
approximately one-half ton of carbon per acre per year for 30 to 40 years.
Organic management and zero emission maintenance equipment mitigate
emissions, reduce costs over time, and increase carbon sequestration.
Electric mowers for playing fields and chalk markers are available.
121 The Lawn Institute. “Carbon Sequestration.” Accessed 2 Feb 2025.
https://www.thelawninstitute.org/environmental-benefits/carbon-sequestration/
120 Woods, M (2016). “Equality, equity and the role of fairness in inclusive sport.” Inclusive Sports Design.
https://www.inclusivesportdesign.com:equality-equity-and-the-role-of-fairness-in-inclusive-sport
Drought122 and desert tolerant123,124 varieties of natural grass appropriate for lawns, parks
and high use playing fields are available.
Grass fields support biodiversity, both above and below the ground.
If Petaluma’s taxpayers, only a small percentage of whom will play on plastic turf, can afford
synthetic turf fields, then organically/regeneratively maintained fields are well within reach.
Three natural grass fields can be installed for the price of one plastic field. With the savings
realized, the city can afford to train a natural turf grass manager and zero emissions equipment,
or even start a college credit high school based program in natural turfgrass management!
124 University of Nevada, Reno. “Turfgrasses for Urban Mojave Desert Landscapes.” UNR Extension,
College of Agriculture, Biotechnology & Natural Resources.
https://extension.unr.edu/publication.aspx?PubID=3320
123 Baird, J (25 Nov 2024). “Drought-friendly UCR turfgrass is now on the market:The newly
commercialized Coachella™ cultivar uses up to 65% less water than California's go-to choice for lawns.”
University of California, Riverside; UCR News.
https://news.ucr.edu/articles/2024/11/25/drought-friendly-ucr-turfgrass-now-market
122 Los Angeles Times (9 Sep 2022). “Column: Has a UC Riverside researcher created the Holy Grail of
drought-tolerant lawns?”
https://www.latimes.com/california/story/2022-09-09/uc-riverside-turfgrass-research-jim-baird
Compiled from : 30 May 2024 Natural Grass Experts125,126
126 Notes on hours of play, costs 30 May 2024
125 Natural Grass Experts webinar (30 May 2024).
https://www.youtube.com/watch?v=E3FEO7vmuCE
Its time to get real!! REAL NATURAL GRASS, proper soil testing, installation and organic
maintenance is the only way to protect residents and visitors to Petaluma. Stop the taxpayer
drain! Do what is right for current and future residents…protect our children and their
grandchildren’s children from the toxic and cancer causing chemicals in and leaching from
synthetic turf. Protect your drinking water from the run-off from plastic fields. Stop the plastic
waste and the microplastic pollution. Stop listening to the greenwashing by those who want to
keep you returning for more of their plastic every 8 to 10 years on average! Regulation is in
process. So, too, will be legislation.
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
From:
To:
Cc:
Subject:
Attachments:
Sent:
Marie/Andrew Molnar
Codes; Town Of Ithaca Planning; Town Of Ithaca Clerks Department;
CJ Randall; Chris Balestra; Marty Moseley;
Pertinent information as we move forward
health effects.png;EU Scientist-Appeal-5G-Moratorium.pdf;Air force
study on emf.pdf;FactSheet Health v1.04.pdf;Safety-of-Wireless-
Technologies-Ver5-020525.pdf;
3/18/2025 3:46:29 PM
WARNING** This email comes from an outside source. Please verify the from
address, any URL links, and/or attachments. Any questions please contact the IT
department
Members of the Planning, Zoning, and Town Boards,
It seems that there may be members of the Ithaca Boards that are still skeptical about cell
radiation negatively affecting health. Since we will likely be dealing with this issue for the
foreseeable future, we want to clear up any misinformation that the telecom industry, and
their allies in the media, have spent millions to spread. One example is the claim that ionizing
radiation can only cause damage through thermal effects. Yet, all the way back in 1988, the US
Air Force revealed that this non-ionizing radiation has nonthermal negative effects
attached): "Experimental evidence has shown that exposure to low intensity radiation can have
a profound effect on biological processes. The nonthermal effects of RF/MW radiation exposure
are becoming important measures of biological interaction of EM fields.” More older
military/government studies can be found here.
It is precisely because of the damaging nature of this radiation that our military has
weaponized this radiation, in the form of "Directed Energy Weapons."
The reality is that there there is significant research pointing to the deleterious health and
environmental effects of exposure to pulse-modulated, microwave radiation. Thousands of
independent, peer-reviewed scientific studies have proven that this radiation harms humans,
causing cancer, neurodegenerative conditions, DNA damage, and a plethora of other health
issues. Children are 2-10 times more at risk than adults.
In an extensive 10-year $30 million study, the National Institutes of Health and the National
Toxicology Program in 2015 concluded that there is indeed a clear link between this radiation
and cancer.
Because of these dangers, insurance companies define electromagnetic fields as a "pollutant" in
the "high risk" category and will not cover them. EMF exclusion clauses are the industry standard.
Because of these studies, the World Health Organization places wireless radiation in the
same category of carcinogen as DDT and lead.
Verizon itself acknowledges the dangers. For example in an annual report to the SEC, Verizon
states: “We are subject to a significant amount of litigation, which could require us to pay
significant damages or settlements…In addition, our wireless business also faces personal injury
and wrongful death lawsuits relating to alleged health effects of wireless phones or radio
frequency transmitters. We may incur significant expenses in defending these lawsuits. In
addition, we may be required to pay significant awards or settlements.”
More worrisome yet, is that most of these studies and conclusions are from existing cell phone
radiation, the new "small cell" technology associated with 5G requires significantly more
transmitting stations than the current technology, causing people to potentially be exposed to
substantially more radiation than existing towers. And the shocking reality is that there is NO
ONE regulating the collective levels of radiation of all these overlapping signals. This is why
thousands of doctors and scientists are warning of the potential health and ecological implications
of 5G. The Chair of the Russian National Committee on Non-Ionizing Radiation Protection (the
group that resolved the Chernobyl disaster), Professor Oleg Grigoriev, compares the 5G rollout to
a “slow Hiroshima”.
There are many other issues with EMF/RF. Studies are now showing the detrimental
environmental effects of this radiation, including on trees, animals, bees, and other
insects, not to mention the significant increase of carbon emissions of this new rollout.
In sum, there is a proven health and environmental risk with any cell antenna. While you
cannot legally mention this in public as Board members (an immoral and unbelievable
contradiction to the very purpose of our codes), you can certainly be aware of the facts.
The future health of Ithacans relies on your being properly informed and embodying the
necessary courage to resist corporate pressure.
Thank you.
Marie and Andrew Molnar
PS: For more in-depth information, see the attached, as well as:
https://www.youtube.com/watch?v=8AfBFiQdgt8
https://www.youtube.com/watch?v=RV9Yk99iJdg
AD-A282 886
AIL-TR-94-53
in-House Report
June 1994
RADIOFREQUENCYIMICROWAVE
RADIATION BIOLOGICAL EFFECTS AND
SAFETY STANDARDS: A REVIEW
Scfit M. Bolon
APWFOR PVJ&C.0FAWD,7R, J7iVNUNLAI7.rr.
Rome Laboratory
Air Force Materiel Command
GrAffin Mr Force Ban, New York
S94-24212 U.G 4Ao 1,3,, A.=.L
ju-0074 1
This report has been reviewed by the Rome Laboratory Public Affairs Office
PA) and is releasable to the National Technical Information Service (NTIS). At
NTIS it will be releasable to the general public, including foreign nations.
RL-TR-94-53 has been reviewed and is approved for publication.
APPROVED: '
JOSEPH J. SIMONS, Chief
Wide Area Radar Surveillance Division
Surveillance & Photonics Directorate
FOR THE COMMANDER: 1 /'4 -.- .
LUKE L. LUCAS, Colonel, USAF
Aoeosslon toy_1Deputy Director, NTIS GrA&I T Surveillance & Photonics Directorate
DTIC TAB- 0Uannounoed [0
jast t tcatio
BY
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REPORT DOCUMENTATION PAGE mV Nooi-aPUM ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o 0704-0MNOW61Ný410PIhpl1~ 1f80A*
i =oddmlsomes"26009 Sulin O tP0 ww
1. AGENY UKE ONLY #Aim U1# .M, DMOAIE FMF TV1, AND DATES COVERED
SJune 1994 In-House Jun 88 -May 93
4, 7MJEQAD ThJLl ILFUIN NUMBERS
RADIOFREQUECY/MICROWAVE RADIATION BIOLOGICAL EFFECTS PE -62702F
AND SAFETY STANDARDS: A REVIEW PR -4506
S.....M TA -14
SbNAHnoR WU -TK
Scott M. Bolen
7. PEWFORINS ORAMA7~A1ON NAME(8) AND A01NESNS) PERIORMING ORGANIZATION
Rome Laboratory (OCDS) REPORT NUMBER
26 Electronic Pky RL-TR-94-53
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Griffiss AFB NY 13441-4514
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S2san, OSSThJTo#MvALAUTY STATEMENT lab OSSTRIBJNON CODE
Approved for public release; distribution unlimited.
136 AS*7PAT#aTm waNn
The study of human exposure to radiofrequency/microwave (RF/MW) radiation has been
the subject of widespread investigation and analysis. It is known chat electro-
magnetic radiation has a biological effect on human tissue. An attempt has been
made by researchers to quantify the effects of radiation exposure on the human
body and to set guidelines for safe exposure levels. A review of the pertinent
findings is presented along with the American National Standards Institute (ANSI)
recommended safety standard (C95.1-1982) and the United States Air Force permissible
exposure limit for RF/140 radiation (AFOSH Standard 161-9, 12 Feb 87). An overview
of research conducted in the Soviet Union and Eastern Europe is also included in
this report.
14. SUBJECT7EM1 I .... m OFPA
RF/NW Hazards, RF/WM Exposure, 11/14W Safety Standards 36
I&aR coal
1?.hSCWCMURA1ON 5.I&ECURTY CIMIIIC4Al1ON IlaveCwCIswIcA11oma. uMIAymO OF ABSTRACT
OF 7Wl PAGE O~~
UNCLASSIFIED UNCLASSIFIED UNCLASSIFIED U/L
FO. MC ..M0ýOvmum
i ii i i i i i i i i i | OW N '
Radiofrequency/Micowave Radiation Biological Effects and Safety
Standards: A Review
Scott M. Bolen
June 1988
Abstract
The study of human exposure to radiofrequency/microwave radiation has been the
subject of widespread investigation and analysis. It is known that electromagnetic radiation
has a biological effect on human tissue. An attempt has been made by researchers to
quantify the effects of radiation on the human body and to set guidelines for safe exposure
levels. A review of the pertinent findings is presented along with the American National
Standards Institute (ANSI) recommended safety standard (C95.1-1982) and the United States
Air Force permissible exposure limit for RF/MW radiation (AFOSH Standard 161-9, 12
February 1987). An overview of research that was conducted in the Soviet Union and
Eastern Europe is also included in this report.
I. INTRODUCTION
In 1956, the Department of Defense (DOD) directed the Armed Forces to investigate
the biological effects of exposure to radiofrequency/microwave (RF/MW) radiation. The
Army, Navy, and Air Force Departments commissioned a Tri-Service Program under the
supervision of the Air Force to meet the DOD directive (14), [15]. The Rome Air
Development Center and the Air Research and Development Headquarters were ultimately
given rspmsibility to manage the program. On July 15-16, 1957 the first of four Tri-
Service Cmferences was held to discuss the effects of RF/MW radiation. These conferences
were the first major effort put forth by the scientific community to explore the biological
effects of exposure to RF/MW radiation [14]. Since then, researchers have discovered a
number of biological dysfunctions that can occur in living organisms. Exposure of the
human body to RF/MW radiation has many biological implications. The effects range from
innocuous sensations of warmth to serious physiological damage to the eye [1], [2], (5], [6],
8], [15]. There is also evidence that RF/MW radiation can cause cancer (81.
The absorption of RF/MW radiated energy causes biological reactions to occur in the
tissue of the human body. In order to determine safe exposure levels and to understand the
effect of RF/MW radiation it is necessary to know the absorption characteristics of the
human tissue. The National Institute for Occupational Safety and Health (NIOSH) (8] has
reported several physical properties that account for energy absorption in biological
materials. Factors which govern energy absorption include: (1) strength of the external
en (EM) field, 2) frequency of the RF/MW source, 3) the degree of hydration
of die tissue, and 4) the physical dimensions, geometry, and orientation of the absorbing
body with respect to the radiation EM field (8]. There is some disagreement among
researchers in determining a specific measure for the dose of RF/MW radiation contracted by
I 1
biological materials. The most commonly accepted measure is the Specific Absorption Rate
SAR). The SAR is defined as the rate at which RF/MW radiated energy is imparted to the
body -typically in units of watts per kilogram (W/Kg) [41. The deposition of energy
specfd in terms of milliwatts per square centimeter (mW/cm2) over the irradiated surface is
alo widely accepted [9].
Based on the known absorption rates and the inherent biological effects of RF/MW
radiated energy, researchers have put forth a number of standards regarding safe exposure
levels. In some instances standards recommended by different examining authorities are in
conflict. For example, the USAF Standard 161-9 (enacted 12 February 1987) allows for a
permissible exposure level of 10 mW/cm2 for persons working in restricted areas and 5
mW/cm2 for persons working in unrestricted areas [10]. The ANSI guideline specifies a
maximum safe exposure level of 5 mW/cm2 over the whole-body area for anyone in contact
with RF/MW radiation [9]. These differences reflect the way in which each examining
authority has interpreted the available RF/MW radiation exposure data.
II. BIOLOGICAL EFFECTS
Exposure to RF/MW radiation is known to have a biological effect on animals and
humans. Damage to major organs, disruption of important biological processes, and the
potential risk of cancer represent the dangers of RF/MW radiation to living organisms.
Pulsed radiation appears to have the greatest impact on biological materials (8].
The response of biological materials to the absorption of thermal energy is the most
pecepble effect of exposure to RF/MW radiation [7]. The energy emitted from an RF/MW
source is absorbed by the- human tissue primarily as heat. In this case, the radiated energy is
disposed in the molecules of the tissue. Dipole molecules of water and protein are stimulated
and will vibrate as energy is absorbed throughout the irradiated tissue area. Ionic conduction
will also occur in the same area where the radiation is incident. It is from these two natural
processes that radiant energy is converted into heat [11]. The thermal effect of continuous
wave (CW) and pulsed radiation is considered to be the same (13].
Nonthermal responses can be less noticeable and are often more difficult to explain
than themmal effects. These responses are related to the disturbances in the tissue not caused
by heating. Electromagnetic fields can interact with the bioelectrical functions of the
irradiated human tissue (8]. Research conducted in the Soviet Union and Eastern Europe
suggests that the human body may be more sensitive to the antheima effects of RF/MW
radiation [3].
There are many reported biological effects to humans and animals that are exposed to
RF/MW radiation. A review of the important findings is given in the following:
A. Heaing Ffm on die SkIn
Most RF/MW radiation penetrates only to the outer surface of the body. This is
especially true for RF/MW frequencies greater than 3 GHz where the likely depth of
penetration is about 1-10 mm (3]. At frequencies above 10 GHz the absorption of energy
will occur mostly at the outer skin surface. Since the therma receptors of the body are
contained primarily in this region, the perception of RF/MW radiation at these frequencies
2
may be similar to that of infrared (1R) radiation [3], [6].
In 1937, J. Hardy and T. Oppel published an investigative paper on the thermal
effects of IR radiation. Their findings were used by Om Gandhi and Abbas Riazi [6] to
explain the thermal effect of RF/MW radiation on the human body (the reference for Hardy
and Oppel can be found in [6]). Figure 1 shows the results obtained from the 1937 report.
As described by Gandhi and Riazi, the findings presented by Hardy and Oppel show that
senaidons of warmth begin to occur when the whole-body is irradiated at a CW power
density of about 0.67 mW/cm2 .Hardy and Oppel based their work on exposure to IR
radiation. From other published reports, Gandhi and Riazi noted that there is a correlation
between the radiating frequency of the incident RF/MW energy and the threshold for
percepion. For example, on an exposed area of the forehead of 37 cnm a perception of
warmth was reported for incident power densities of 29.9 and 12.5 mW/cm2 from sources
radiating at 3 and 10 GHz respectively [6].
Other observations made by Hardy and Oppel showed that when smaller body areas
were irradiated, larger power densities were required to stimulate the thermal receptors in the
skin. Gandhi and Riazi were able to confirm this result with reports from recent papers.
They found that irradiation of an exposed body area of 40.6 cm2 to a power density of about
21.7 mW/cm2 yielded the same thermal perception as did the irradiation of a smaller body
area of 9.6 cm2 to a power density of about 55.9 mW/cm2 .Hardy and Oppel reported that
thermal sensations occurred within about 3 seconds after irradiation of the body tissue. More
recent findings indicate a reaction time of closer to I second (6].
Gandhi and Riazi (6] have also reported that the depth of penetration of RF/MW
radiation has an impact on the power density threshold needed to stimulate the perception of
warmth. As a comparison, IR radiation will not penetrate the outer body surface as deeply
as RF/MW radiation emitted at a frequency of 2.45 GHz. Clinical observations have shown
that irradiation of the ventral surface of the arm by an RF/MW source radiation at 2.45 GHz
will cause a sensatki of warmth when the incident power density is about 26.7 mW/cm 2 .
For incident IR radiation a perception of warmth occurs at a power density of 1.7 mW/cm2 .
They estimated that at millimeter wavelengths the perception of warmth may occur at a
power density level of about 8.7 mW/cm 2 .
Exposure to higher levels of radiation can cause serious biological effects. Because of
the physical dimensions and geometry of the human body, RF/MW radiated energy is
nonuniformily deposited over the whole-body surface. Some areas on the skin and outer
body surface will absorb higher amounts of the radiated energy. These areas will be marked
by "hot spots" of high temperatures (7], [11], (16]. Experiments conducted on laboratory
animals have shown, that skin burns typically occur in the areas of hot spots. The
penetration of RF/MW radiation also causes skin burns to be relatively deep [11]. In
P erIments sponsored by the Tri-Service Commission, it was reported that RF/MW
radiation burns over the nrb cages of dogs caused severe subcutaneous damage that did not
visibly appear for weeks after the injury was sustained [20]. Burns can cause increased
vascular permeability. This can lead to significant losses of body fluids and electrolytes.
Serious burns can suffer fluid losses for a few days. Blood circulation can be altered in the
effected area and other biological functions could be indirectly affected [12].
B. Wfole-Body Hyperthennia
3
Thermal energy absorbed by the whole-body can cause a rise in body temperature.
When the human body is irradiated by an RF/MW source at an incident power density of 10
mW/cm2 there will be a rise in body temperature of about P C. The total thermal energy
absorbed at this power density is about 58 watts. Typically, at rest the human basal
metabolic nrt is about 80 watts and it is about 290 watts during periods of moderate activity.
Exposure of the human body to low power RF/MW radiation does not appear to impose any
appreciable thermal hazard. These figures were reported by The U.S. Department of Health,
Education and Welfare [3].
Adverse biological effects can occur when the body is subjected to high doses of
RF/MW radiation [161. In this instance large amounts of thermal energy can be absorbed by
the body. A dramatic influx of energy can overburden thermoregulatory mechanisms. If
excess heat cannot be exhausted the core temperature of the body will rise to a dangerous
level resulting in hyperthermia [12], [16]. The biological response to excess heat buil'up is
the dilation of blood vessels at the surface of the skin and the evaporation of water through
sweating. These are the primary mechanisms for heat dissipation. Hyperthermia can cause
severe dehydration and the loss of electrolytes such as sodium chloride. Other harmful
effects include fever, heat exhaustion, and heat fatigue. Heat stress is the most serious
consequence of hyperthermia. Cardiac failure and heat stroke can result from heat stress
12].
It has also been noted that hyperthermia may cause injury to blood-brain barrier
BBB) [19]. This barrier refers to the several biological materials that separate the essential
elements of the central nervous system from the blood [18]. High cerebral temperatures
exceeding 439C may damage the BBB. The result can be a disruption of blood vessel
continuity or integrity and degradation of the flow of blood and other body fluids in the brain
191.
C. Local Hype/hermda
The nonuniform deposition of RF/MW radiated energy over the whole-body surface
causes the body to be heated unevenly. Local areas where temperatures rise above 41.6 0C
can experience damage to the tissue [161. In these areas it is possible that harmful toxins
could be released as result of the high temperatures. Heating can cause cell membranes and
blood capillaries to become more permeable. An increase in capillary permeability can lead
to a loss of plasma proteins. The denaturation of proteins can also occur within cells [111,
16]. This can lead to changes in the physical properties and biological functions of proteins
18]. Dernauration of proteins can also cause polypeptide and histamine-like substances to
become active [11], [16]. Histamines can stimulate gastric secretion, accelerate the heart
rate, and cause the dilation of blood vessels resulting in lower blood pressure [18]. Areas of
the body where blood circulation is poor or where thermal regulation is insufficient, are
more susceptible to injury [11].
D. Carcinogenic Fifects
The carcinogenic effects of exposure to RF/MW radiation are not well known. It is
difficult to clinically establish a link to cancer. The problem that researchers have in linking
4
RF/MW radiation to cancer is that the disease itself is prevalent and can be caused by a
variety of environmental factors. In fact cancer is the second leading cause of death in the
United States. There are, however, published reports that reveal some insights into the
carcinogenic nature of RF/MW radiation. Nonthermal effects may provide important clues
to the u 1dr1nig of carcinogenic reactions in the human body [8],[32].
i. PathologicalReports
In 1962, S. Prausnitz and C. Susskind reported experimental results that showed an
increase in cancer among test animals exposed to RF/MW radiation. In the experiment, 100
male Swiss albino mice were irradiated by a 10 GHz RF/MW source at an incident power
density of about 100 mW/cm2 . The mice were exposed for 4.5 minutes/day, 5 days/week for
a total of 59 weeks. It was noted that irradiation caused the whole-body temperature of the
mice to rise about 3.3TC. Upon examination, it was found that 35% of the mice had
developed cancer of the white blood cells. The disease was observed as monocytic or
lymphatic leucosis or lymphatic or myeloid leukemia. Only 10% of a similar control group
had developed cancer [21].
There have been a few allegations that RF/MW radiation has induced cancer in
humans [8], [151. The NIOSH Technical Report [81 cites charges made in the early 1970's
against Philco-Ford and The Boeing Corporation that occupational exposure to RF/MW
radiation caused cancer among employees. One incident was reported at each company. At
Philco-Ford it was claimed that exposure caused a rare form of brain cancer to manifest in
one worker that eventually resulted in death. In each case, there was no scientific proof that
RF/MW radiation had induced cancer in the company employees. There was also a report
that EM fields induced cancer in an individual that worked at the U.S. Embassy in Moscow.
Again, there was no scientific evidence that supported the claim [8].
Recently, the Observer Dispatch, a local newspaper published in Utica, New York,
reported that a major study has just been completed in Sweden. The study concluded that
children who live near high power lines have a greater risk of developing leukemia than
children who live farther away from the power lines. The study involved 500,000 people
and provided some evidence to link the electromagnetic fields produced by low frequency
power lines to cancer. The researchers, however, cautioned against drawing firm
conclusions as a result of the research [33]
ii. ffect on Chromosomes
It has been observed that disturbances in chromosomic activity can cause cancerous
aberrations to occur in the human body. In 1974, a paper published by K. Chen, A. Samuel,
and R. Hoopingarner (reference found in [8]) reported that chromosomal abnormalities can
be linked to chronic myeloid leukemia. Serious genetic mutations can also result from such
abnormalities that can lead to malignancies in the tissue [8].
In 1976, A. A. Kapustin, M. I. Rudnev, G. I. Leonskaia, and G.I. Knobecva
reference found in [17]) reported alterations in the chromosomes of bone marrow cells in
laboratory animals that were exposed to RW/MW radiation. They exposed inbred albino rats
to a 2500 MHz ,F/MW source at incident power density levels of 50 and 500 uW/cm2 .
Irradiation lasted for 7 hours/day for 10 days. Upon examination of the animals, they
5
observed chromosomal anomalies that appeared in forms described as polyploidy,
aneuploidy, chormatic deletion, acentric fragments and chromatic gaps [17].
The NIOSH Technical Report [8] summarizes the findings of several researchers.
Chtomosomal and mitotic anomalies have been observed in a variety of animal and human
cells for varying exposures to RF/MW radiation. Pulsed and CW radiation ranging in
frequency from 15 to 2950 MHz and power densities from 7 to 200 mW/cm2 have caused
abnormalities to occur in chromosomes. The reported affects include: linear shortening of
the chromosomes, irregularities in the chromosomal envelope, abnormal bridges and
stickiness, translocations, chromosomal breaks and gaps, chromatid breaks, acentric
chromosomes, dicentric chromosomes, deletions, fragmentation, and ring chromosomes [8].
iii. Mutagenic Effects
Reported evidence indicates that biological interaction with EM fields can cause the
formation of mutagens in cells. In 1974, three Soviet researchers, Danilenko, Mirutenko,
and KIudrenko (reference found in [8]) published results showing a mutagenic effect of
RF/MW radiation. Mutagens were observed to form in cells that were irradiated by a pulsed
RF/MW source operating at 37 GHz and 1 mW/cm2 power intensity. They concluded that
irradiation of tissue by pulsed RF/MW sources causes cell membranes to become more
permeable to destructive chemical mutagens [8].
Results published in 1963 by G. H. Mickey (reference found in [8]) showed
hereditary changes to occur in drosphila germ cells that were exposed to pulsed modulated
RF/MW radiation for carrier frequencies between 5-40 MHz [8]. Evidence of RF/MW
induced teratogenesis in animals has also been reported by researchers. The effect of
exposure to CW radiation was observed by Rugh and McManaway in 1976 (reference found
in [8]). They found gross congenital abnormalities in rodent fetuses that were irradiated by a
2450 MHz RF/MW source at an incident power intensity of 107.4 mW/g [8].
iv. Lymphoblastoid Transformations
Lymphoblastoid Transformations refer to changes in the physical nature of
lymphoblasts. Mature lymphoblast cells (i.e. lymphocytes) participate in the immune system
of the body (18]. Lymphoblastoid transformations induced by RF/MW radiation appear to
be similar to transformations present in disorders contributing to abnormal growth in
lymphoid tissues and in certain types of leukemia. RF/MW radiation induced
transformations, however, do not appear to be malignant and are not likely to spread among
healthy cells (8].
W. Stodlink-Baranska reported (reference found in [8]) lymphoblastoid
transformations to occur when human lymphocyte cells were exposed to a 2950 MHz pulsed
RF/MW source at power density levels of 7 and 20 mW/cm 2 .In 1975, P. Czerski also
reported (reference found in [8]) observing lymphoblastoid transformations after irradiation
of purified human lymphocyte suspensions by an RF/MW source radiating at 2950 MHz for
variable power density levels. In addition, Czerski reported acute transformations occurring
in adult mice and rabbits that were irradiated by a pulsed RF/MW source radiating at 2950
MHz and at low power density levels of 0.5 and 5 mW/cm2 respectively [8].
6
v. Oncogemc Effects
Oncogenic effects have been linked to imbalances in the regulatory mechanisms of the
body. A 1974 report published by E. Klimkova-Deutschova (reference found in [8]) claimed
that persons exposed to RF/MW radiation experience biochemical reactions. The report
indicated alterations in fasting blood sugar levels, a decrease in the ability to dispose of
normal metabolic waste, and depressed serum levels of pyruvate and lactate. These
bioche mical reactions point to the possibility of regulatory malfunctions occurring in the
body. It has been suggested that certain regulatory imbalances may promote the growth of
tumors. A change in hormonal levels has been observed to cause oncogenic effects in tissues
that require hormonal balances to function properly. The presence of hormones in other
tissue areas may effect the development of existing tumors in those areas [8].
E. CardiovascularEffects
Most of the cardiovascular effects of RF/MW radiation have been reported by
researchers in the Soviet Union and Eastern Europe. Soviet investigators claim that exposure
to low levels of RF/MW radiation that are not sufficient to induce hyperthermia can cause
aberrations in the cardiovascular system of the body [7].
One experiment performed on rabbits indicates that several types of cardiovascular
dysfunctions could be possible. An RF/MW source radiating at 2375 MHz was used to
irradiate rabbits for a test period of 60 days under varying field intensities. For field
strengths ranging from 3-6 V/M researchers noted a sharp increase in the heart rate of the
animals. This effect was observed to subside with time. Exposure to field strengths of 0.5-
1.0 V/M caused the heart rate to become slower than normal. No effect was reported for
rabbits that were exposed to EM field intensities below 0.2 V/M [17]. Other effects that
have been observed by Soviet researchers, are alterations in EKG and low blood pressure
7], [17].
The NIOSH Technical Report [8] references a Soviet study published in 1974 by M.
N. Sadcikoiva that suggests some connection between RF/MW radiation exposure and the
potential for cardiovascular disturbances in humans. Researchers examined 100 patients
suffering from radiation sickness. It was found that 71 of the patients had some type of
cardiovascular problem. Most of these patients had been exposed to RF/MW radiation for
periods ranging from 5-15 years. A smaller group of patients exposed for shorter time
periods also experienced cardiovascular irregularities. The study concluded that there is a
probable link between exposure to RF/MW radiation and cardiovascular disease [8].
F. The North Karelian Project
In response to earlier Soviet reports, the World Health Organization (WHO) decided
to conduct a comprehensive study on the biological effects of exposure to RF/MW radiation.
In 1976, M. Zaret published the results of the study (reference found in [8]). The WHO
investigation focused on the population of North Karelia, a remote area of Finland that
borders the Soviet Union. This region was selected because of its close proximity to a then
Soviet early warning radar station. North Karelia is geographically located in the path of
intercontinental ballistic missiles that would originate from the midwest United States. To
7
detect these missiles, the Soviets constructed a number of high power tropospheric scattering
radar units adjacent to nearby Lake Ladoga. The operation of these units exposes the
residents of North Karelia to large doses of ground and scatter radiation. The WHO
negifound evidence linking exposure of RF/MW radiation to cardiovascular disease
and cancer. The North Karelian population suffered from an unusually high number of heart
attacks and cases of cancer. In addition, it was found that the affliction rate of these diseases
was much higher among residents living closest to the radar site [8].
G. Hematologic Effects
There is evidence that RF/MW radiation can effect the blood and blood forming
systems of animals and humans. Experiments conducted in the Soviet Union have indicated
changes in blood cell levels and alterations in the biological activities of hematologic
elements. Other investigators have reported similar effects [7], [8], [17].
The results of an experiment reported in 1979 by V. M. Shtemier showed a decrease
in the biological activity of butyryl cholinesterase in rats that were exposed to pulsed
RF/MW radiation (reference found in [17]). The experiment subjected 15 rats to a 3000
M&z pulsed RF/MW source with an incident power density of 10 mW/cm2 .The rats were
irradiated for I hour/day over several days. After 42 days, there was a loss of biological
activity of the butyryl cholinesterase enzyme caused by a decrease in the concentration of the
enzyme in the bloodstream of the rats [17]. Cholinesterase is a catalyst in the hydrolysis of
acetylcholine into choline and an anion. Choline is a useful enzyme that prevents the
deposition of fat in the liver [181.
In another experiment, 20 male rats were exposed to a 2376 MHz pulsed RF/MW
source with an incident power density of 24.4 mW/cm2. Each rat was exposed for 4
hours/day, 5 days/week for 7 weeks. Blood samples were taken periodically and examined
for anomalies. After repeated exposures, it was discovered that the number of lymphocytes
and leukocytes (white blood cells) in the bloodstream of the rats was lower than normal.
The biological activity of alkaline phosphatase in neutrophil leukocytes was also found to
increase when the rats were irradiated [17].
The results of several other experiments are summarized in the NIOSH Technical
Report [8]. RE/MW radiation has been observed to cause: an increase in the amount of
exudate in bone marrow, the transient disappearance of fat cells from bone marrow,
destruction and loss of essential bone marrow cells, underdeveloped marrow, a decrease in
the number of red blood cells, and an imbalance in the number of lymphocytes in the
bloodstream [8].
H. Effect to the Central Nervous System
There is documented evidence that exposure to RF/MW radiation can cause a
disturbance in the central nervous system (CNS) of living organisms [3], [8], [11], [17].
Soviet investigators claim that exposure to low-level radiation can induce serious CNS
dysfunctions. Experiments conducted in the Soviet Union and Eastern Europe have exposed
live subjects to radiation levels that are near or below the recommended safe levels
prescribed by the ANSI Standard and the USAF AFOSH Standard [17].
8
i. Pathological Repor
Soviet investigators claim that the central nervous system (CNS) is highly sensitive to
RP/MW radiation [3], [8], [11], [17]. The NIOSH Technical Report [81 summarized the
results of a pathological study published by A. A. Letavet and Z. V. Gordon in 1960. The
rreported that several CNS related disorders were discovered among 525 workers
exposed to RF/MW radiation. The symptoms were listed as: hypotension, slower than
normal heart rates, an increase in the histamine content of the blood, an increase in the
activity of the thyroid gland, disruption of the endocrine-hormonal process, alterations in the
sensitivity to smell, headaches, irritability, and increased fatigue. Other researchers have
acknowledged similar biological responses [8].
ii. Sovet Union Erpermenmal Resuls
Several experiments have been performed in the Soviet Union and Eastern Europe
that demonstrate a variety of biological effects that can occur in living organisms.
observations of laboratory animals subjected to low power EM fields showed alterations in
the electrical activity of the cerebral cortex and disruptions in the activity of neurons [17].
L. K. Yereshova and YU. D. Dumanski (reference found in [17]) exposed rabbits and
white male rats to a continuous wave 2.50 GHz RF/MW source. The animals were
irradiated for 8 hours/day over a period of 3 to 4 months at power density levels of 1, 5, and
10 uW/cr 2.It was observed that rabbits exposed to the 5 and 10 uW/cm 2 power density
levels suffered alterations in the electrical activity of the cerebra cortex and distufrb ces to
the conditioned reflex response. They concluded that exposure to RF/MW radiation caused
perturbations in the higher functioning centers of the CNS in the laboratory animals (17].
An experiment conducted by V. R. Faytel'berg-Blank and G. M. P;.revalov
demonstrated the biological effects of RF/MW radiation on the activity of neurons (reference
found in [17]. They subjected chinchilla rabbits to a 460 MHz RF/MW source at incident
power densities of 2 and 5 mW/cm2 .Only the heads of the rabbits were irradiated and
exposures lasted for 10 minutes. Exposure at the 2 mW/cm 2 power density level caused
neuronal activity to increase and evoked an electroencephalogram (EEG) activation reaction.
Neuronal activity was observed to decrease at the higher power density level. These results
indi'•ated that RF/MW radiation can cause neurophysiological alterations in animals. These
biological responses may be dependent on the intensity of the radiation (17].
iii. Behavioral Effects
Exposure to RF/MW radiation has been observed to cause a disruption in the behavior
of animals. Experiments conducted on rats and nonhuman primates indicates that conditioned
responses can be altered as a result of irradiation. Researchers indicate that behavior may be
the most. sensitive biological component to RF/MW radiation [1], [7], [9], (29].
D. R. Justesen and N. W. King (reference found in [7]) reported experimental results
that demonstrated a degenerative behavioral effect in laboratory animals that were exposed to
RF/MW radiation. The results were published in 1970. They exposed rats to a 2450 MHz
multimodal resonating cavity system. Exposure was periodic with irradiation times lasting
for 5 minutes and recurring every 5 minutes. This cycle as sustained for 60 minutes. The
9
experiment tested the effect of irradiation at whole-body energy absorption rates of 3.0, 6.2,
and 9.2 W/Kg. It was observed that for a SAR of 6.2 W/Kg the behavioral performance of
the rats degraded significantly and activity usually terminated at the end of the 60 minute
exposr period [7.
In 1977, James Lin, Arthur Guy, and Lynn Caldwell [29] reported experimental
results that showed alterations in the behavioral response of rats that were exposed to
RF/MW radiation. White female rats were trained to execute a *head raising" movement in
return for a food pellet. The total number of such movements was counted during each
exposure session in order to quantify the effect of irradiation. The animals were exposed to
a 918 M]z RF/MW source at power density levels of 10, 20, and 40 mW/cm 2.Clinical
observation showed that baseline responses remained unchanged for irradiation at the lower
power density levels of 10 and 20 mW/cm2.At 40 mW/cmn, however, behavioral responses
decreased rapidly after 5 minutes of continuous exposure. After about 15 minutes of
exposure, behavioral activity terminated. It was determined that the peak energy absorption
at 40 mW/cm 2 was about 32 W/Kg and the average absorption was 8.4 W/Kg over the
whole-body surface [29].
iv. Synergetc Effect of Drugs RF/MW
Radlaton
In 1979, 1. R. Thomas et al. reported that psychoactive drugs and RF/MW radiation
may have a synergetic effect on living organisms (references for Thomas can be found in
1D. Experiments were conducted on laboratory animals. Male albino rats were
administered dextroamphetamine and irradiated with a pulsed 2450 MHz RF/MW source at 1
W/cm? power intensity for periods of 30 minutes. It was found that the number of clinical
responses observed per minute in the rats diminished more rapidly under the stimulus of both
agents than in the control condition where just the drug was administered. This indicates that
the effects of RF/MW radiation may be enhanced by certain drugs [1].
v. Analeptic Effect in Animals
Pulsed RF/MW radiation was reported to have an analeptic effect in laboratory
animals. Experimental results presented by R. D. McAfee in 1971 showed that anethesized
animals could be awakened by irradiation from a pulsed 10 GHz RF/MW source. The
energy incident on the test animals was estimated to have a power density of between 20-40
mW/cm 2.Experiments conducted on rats showed that these animals were aroused from
states of deep sleep by irradiation. It was observed that the blood pressure of a rat decreased
simultaneously with the arousal response and that laryngeal spasms would occur when the rat
was awakened. McAfee reported that the laryngeal spasms would obstruct the airway
causing convulsions, asphyxiation, and eventually death. Other experiments performed on
rabbits, cats, and dogs showed that these animals could also be awakened by irradiation.
The larger animale, however, did not asphyxiate themselves, The blood pressure of the dogs
and cats was observed to rise as they were awakened. In all cases, the arousal response was
stimulated only when the head of the animal was irradiated. The body temperature of the
test animals was not observed to rise as a result of irradiation. This indicates that the
analeptic effect of RF/MW radiation may be nonthermal in nature [201.
10