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HomeMy WebLinkAboutFinal comments 3.18.25 PB meeting GFRFrom: 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 **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 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 **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 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 10 Date December 19th, 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 ³ 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 10 Date December 19th, 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 μFTIR 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