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Home My WebLink AboutCombined comments after PB mailout until noon-day of 3.18.25 PB meetingFrom: To: Subject: Sent: Jill Kellner Town Of Ithaca Planning artiﬁcial turf at Cornell 3/17/2025 8:38:44 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, I live at 1321 Ellis Hollow Road and am very concerned that you would allow Cornell to consider using artificial turf on their fields. It is a threat to us all. The August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification.This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee.Additionally, I want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment.Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Jill Kellner 1321 Ellis Hollow Road References: 1. Lowell Center for Sustainable Production, University of Massachusetts Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Academic, Municipal, and Other Testing Efforts. August 2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in- Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18- 386957.pdf?rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0. The compilation of PFAS testing from academic, municipal, and independent studies confirms that PFAS have been detected in all components of artificial turf, including turf blades, carpet backing, infill, shock pads, adhesives, and even product packaging. Total fluorine (TF) testing consistently found fluorine across various samples, with concentrations ranging from 16 to 661 µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated coatings, or PFAS-based processing aids. Extractable PFAS tests detected long- and short-chain PFAS in multiple studies, particularly fluorotelomer alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS precursors in adhesives and shock pads. Municipal and nonprofit-led testing further corroborates these findings, with PFAS measured in stormwater runoff, installation materials, and artificial turf fields marketed as ‘PFAS-free.’ These results highlight significant gaps in industry claims and emphasize the need for stricter regulations and improved testing methodologies to assess the full extent of PFAS contamination in artificial turf systems. 2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth, NH. October 22, 2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas- statement-fieldturf-1.pdf A supplier for FieldTurf/Tarkett Sports claims that their artificial turf filaments/fibers are fluorine-free and do not contain PFAS, including PFOS, based on manufacturing consistency and compliance with REACH regulations. However, the declaration lacks total fluorine testing, does not specify PFAS detection limits, and does not test the full turf system, meaning polymeric PFAS or precursors could still be present. Additionally, there is no independent third-party verification, making the PFAS-free claim scientifically weak and incomplete. 3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Zero Waste Ithaca Bibliography. Updated March 16, 2025 https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM- s_4bfbmO26R-Q/edit?usp=sharing From: To: Cc: Subject: Sent: Louise Mygatt Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org artiﬁcial turf 3/17/2025 12:06:06 PM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town Planning Board Members, The attached August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification. This raises an important question: What kind of PFAS-free guarantee does TenCate— the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee. Additionally, I want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Dr. Louise Mygatt Dear Town Planning Board Members, The attached August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. I am so grateful for to see the studies that ZWI have provided our community from their legitimate, scholarly research that exhibits how horrifying this turf project is. CAN YOU LIFT YOUR HEAD OUT OF CORNELL’S DECEPTION AND SEE IT? WE WILL NOT STAND FOR THIS!!!!! Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. It’s absolutely beyond the pale that this institution that proclaims itself as a leader in scientific research would represent themselves in such a horrifying manner. TRULY. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I appeal to each of you on this board who have shown your interest and dedication to making Ithaca healthy and safe. I know who you are, and I want you to use your voice to REQUEST a deeper study goes into this. DO NOT let Cornell bully you! I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification. This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee. I also want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment. And one last piece: Cornell also plans to do “independent” testing in addition to the manufacturer’s “PFAS-free” guarantee, but the testing will be done before it leaves the manufacturer, with zero specifications about testing method, threshold, etc - really confidence inspiring, according to page 10 of Supplemental Materials Submission dated January 31, 2025. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Do what’s right, people. THIS REQUIRES A COMPLETE ASSESSMENT! Sincerely, Caroline Ashurst PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1 Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts August 2024 A number of organizations have conducted PFAS testing in artificial turf materials. These include academic studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or vendors, sometimes with the assistance of consulting firms. This document provides a compilation of results that have been reported from many of these testing efforts. This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in artificial turf, and for a discussion of key considerations related to test methods. For another recent summary of test results, see the New Jersey Department of Environmental Protection’s Technical Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3 Test results are summarized below for academic studies; regional and municipal studies; nonprofits, community organizations, and journalists; and manufacturers. Testing has been carried out using a variety of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or precision of the methods or results. Academic studies Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and expanded the information available on the presence of PFAS in these materials. Results from these studies are summarized in Table 1. Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm, Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork, bark, and coconut). TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently. The authors explain that “collectively, these results point toward polymeric organofluorine (e.g., fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4 PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2 Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be landfilled or incinerated. Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography- mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb rubber infill. Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf blades to determine the presence of PFAS.6 For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the manufacturing process. Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that “much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing literature. Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." This information further supports the possibility that fluorinated polymers were added to the resin. A TOP assay was performed on four samples including artificial turf and product packaging. Because this testing included both artificial turf and other plastic products, this information is relevant primarily for refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did not have significant changes in concentration after oxidation. This was likely because those samples did not contain substantial quantities of the precursor PFAS that break down into the degradation products that were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and showed a higher concentration of degradation products after oxidation. This suggested that the sample contained higher quantities of the precursors that were measured in the TOP assay. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3 A conclusion of this study was that “these results suggest that much of the total fluorine signals measured in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various plastic products.” In other words, this study further supports the importance of carefully choosing test methods that can accurately characterize PFAS content in artificial turf materials. Table 1. Summary of PFAS testing from academic studies. Source Summary Lauria et al. (2022)4 Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing, carpet blades, and infill. TOTAL FLUORINE • “TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 μg of F/g in backing, filling, and blades, respectively).” • TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic material infills. EXTRACTABLE ORGANIC FLUORINE • Backing: range from <LOD - 145 ng of F/g (ppb) • Infill: range from <LOD - 179 ng of F/g (ppb) • Blades: range from <LOD - 192 ng of F/g (ppb) TARGETED ANALYSIS • Results were reported as the sum of fluorine in a sample. • Backing: <LOD - 0.63 ng of F/g (ppb) • Infill: <LOD - 0.15 ng of F/g (ppb) • Blades: “absent” Zuccaro et al. (2023)5 A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH) in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM). FLUOROTELOMER ALCOHOLS PILOT TEST: • “8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at concentrations of 1.0 and 0.71 ng/μL [ppm], respectively. This translates to 300ng 8:2 FTOH/g artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH were not found to be present in detectable levels.” Whitehead (2023) (dissertation)6 Analyzed PFAS in 27 samples of artificial turf blades using several methods. TOTAL FLUORINE • Measured using particle-induced gamma ray emission (PIGE) spectroscopy. • TF ranged from <LOD to 2.94 µg F/cm2. TARGETED ANALYSIS Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC- MS/MS) PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4 • PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). ORGANIC FLUORINE • Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." TOP ASSAY (four samples only) • “[T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t have significant changes in their sum of PFAS concentrations. The sample which had the highest sum of PFAS concentrations before TOP assay showed a more significant increase in measured concentrations.” • Results suggest that “the concentrations of fluorine measured through PIGE are likely indicative of PFAS which does not undergo transformation” into the compounds measured in the TOP assay. Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Regional and Municipal Studies The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and two adhesives used during the installation of an artificial turf field.7 The analyses included targeted analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both organic and inorganic analytes present in liquids, soils, and wastes."8 PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in the carpet, and lower quantities in other materials. Additional results are summarized in Table 2. The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial grass.”9 The City of Portsmouth later initiated further testing with help from a consulting group. This effort included a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis. The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill, the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are summarized in Table 2. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5 Table 2. Summary of PFAS testing led by regional institutions and municipalities. Source Summary Martha’s Vineyard, MA (2020).7 Laboratory results interpreted by consultants at Tetra Tech Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives used during field construction. TARGETED ANALYSIS “Total PFAS by isotope dilution method” • Detected certain PFAS at concentrations above the method detection limit (MDL) but below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb); Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb). Synthetic Precipitation Leaching Procedure • “Select PFAS compounds were detected in the SPLP analysis that were not detected in the total PFAS analysis.” • “The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L), [shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the [adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are equivalent to ppt.) • “The detection of PFAS compounds in the samples of the synthetic turf components via SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain PFAS compounds that were not extractable via the analytical method utilized for total PFAS analysis (isotope dilution method), but were extractable by the more rigorous SPLP extraction process.” TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY • PFAS were not detected during the pre-oxidation measurements. • The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all sample materials at concentrations above the method detection limit but below the reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g. • “Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill] at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)” • “Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at a concentration of 6.08 ng/g.” This concentration was above the method detection limit but below the reporting limit, yielding an estimated value. TOTAL ORGANIC FLUORINE • “Total organic fluorine was detected in the [carpet] at a calculated concentration of 70 parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting that the total fluorine detected in these samples likely represents primarily organic fluorine. However, because the RL in some cases is close to the detected concentration of total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine was not detected in the sample of the [wood infill] above the RL of 10 ppm.” Additional note from consultant report The consultant noted that there were difficulties in the laboratory’s approach. “The detection limits achieved by the laboratory were elevated because of the limited sample weight utilized during extraction and the dilutions required by the low density sample matrix.” PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6 Portsmouth, NH (2021) initial community testing9 The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center, initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad. An independent laboratory measured total fluorine in these materials. TOTAL FLUORINE • Carpet: TF: 83- 119 ppm • Backing: TF: 16 ppm • Shock pad: TF: 61 ppm • Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total fluorine measurements are typical for plastics that have been manufactured with PFAS- based polymer processing aids – which will leave residues of these PFAS at the part-per- million level on the artificial grass.” 9 Portsmouth, NH (2022) testing initiated by City of Portsmouth. Laboratory results interpreted by consultants at TRC10 Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock pad. Results summarized here show presence of substances only. See full report for concentrations. TARGETED TESTING AND TOP ASSAY PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70 individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope dilution liquid chromatography/dual mass spectrometry” in samples of material. This method is considered a targeted test method. Samples were also oxidized and measured for PFAS precursors. • Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples. • Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].” • Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was also detected in a blank sample). Six PFAS were detected in samples after oxidation. • Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation. NON-TARGETED ANALYSIS “Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were performed on each sample to determine if “other” PFAS were present that were not included in the analysis of the 70 individual PFAS.” • Results were “qualitative estimations of presumptive positives.” Several additional chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl) carbonate, was tentatively identified in the carpet sample. The other chemicals were reported as “unknown.” Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7 Nonprofits, Community Organizations, and Journalists A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial turf. Below are some examples. Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11 The organizations tested backing of both new turf and older, discarded turf. They also tested a number of samples of artificial grass blades (carpet fibers). They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS. They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is a long-chain PFAS that is no longer manufactured in the US due to concerns about health and environmental effects. They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of fluorine that suggest the presence of PFAS.11 Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted samples of new and older turf to commercial and research laboratories for various types of PFAS analyses. Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS- free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS measured after installation were higher than the levels measured before installation. Three other PFAS were also detected in the post-installation stormwater samples (see Table 3). Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8 Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists. Source Summary NONPROFIT AND COMMUNITY ORGANIZATIONS Testing reported in The Intercept (2019).11 Results summarized by New Jersey Department of Environmental Protection.2 Targeted and total fluorine testing conducted on new turf carpet samples; targeted testing conducted on used sample. TARGETED ANALYSIS • New turf carpet sample: 6:2 FTSA: 300 ppt • Used turf carpet sample: PFOS: 190 ppt TOTAL FLUORINE ANALYSIS • New turf carpet blades: 44-255 ppm Woodbridge, CT (2021)12 Samples of stormwater runoff were collected before and after the installation of an artificial turf field from a swale located near the artificial turf field installation site. Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS. TARGETED ANALYSIS of runoff • Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt) • After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L (ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt) Preliminary dermal exposure tests by Public Employees for Environmental Responsibility (PEER)13 Used skin wipes to measure PFAS on four individuals before and after play. Results showed differences in pre- and post-play PFAS levels for artificial turf and grass. Center for Environmental Health (CEH)14,15 CEH tested samples of artificial grass used for residential applications. PFOS was detected during testing. Based on the levels detected, CEH sent California Proposition 65 notices of violation to relevant parties. JOURNALIST Philadelphia Inquirer (2023)16 The Philadelphia Inquirer purchased samples of artificial turf carpet used by Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS. TARGETED ANALYSIS • Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Manufacturers Determining which chemicals are present in a product can be challenging because chemical contents are frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9 manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of two manufacturers that have provided test data. As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was detected above this threshold. Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts consulted by the journalists suggested that the laboratory test results had limited value, in part because of high detection limits.18 In some cases, targeted tests have been used to inform PFAS-free statements. For example, one manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at 100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17 In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term “PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100 ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile products.21) Table 4. Examples of PFAS testing led by manufacturers. Source Summary Artificial turf manufacturer example #1 (2023)17 The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The lowest calibrated detection is at 100 parts per trillion.” TARGETED ANALYSIS OF PFOA AND PFOS • PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect concentrations below 100 ppt. Artificial turf manufacturer example #2 (2022)22 Results summarized by The Philadelphia Inquirer (2024)18 The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI Laboratories Inc. for targeted PFAS testing. TARGETED ANALYSIS • The laboratory’s summary of results stated that “all extractable PFAS compounds were non-detect at a level of 2-4 ug/kg (ppb).”22 • Experts consulted by The Philadelphia Inquirer expressed concerns about the testing methods and the high detection limits used. They noted that lower detection limits and a total organic fluorine test would have yielded results that are more informative.18 Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10 Acknowledgments This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger- Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather Whitehead, PhD. This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection, State of New Jersey. Research for this report was supported by The Heinz Endowments. The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative strategies for communities and workplaces to adopt safer and sustainable practices and products to protect human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions, and government agencies to build healthy work environments, thriving communities, and viable businesses that support a more sustainable world. References 1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18- 385224.pdf (July 2024). 2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023). 3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023). 4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672. 5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols (FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280. 6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant to human health and the environment (dissertation), https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023). 7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report, https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL (February 2021). 8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure, https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024). 9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021, https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new- synthetic-turf-field/ (2021). PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11 10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf, https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf (2022). 11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019, https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October 2019). 12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021., https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021). 13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin, https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024). 14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act: Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document., https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024). 15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024., https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024). 16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed. Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas- forever-chemicals-cancer-20230307.html (2023). 17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp- content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024). 18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial- turf-field-murphy-recreation-20240223.html (23 February 2024). 19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and- artificial-grass/ (2023, accessed 5 June 2024). 20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/. 21. State of California. CA Health & Safety Code § 108945, https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha pter=12.5.&article= (2022). 22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022, https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022). From: To: Cc: Subject: Attachments: Sent: AKWilson Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org Comments on Field Hockey Turf on Game Farm Road Site PFAS detected in all components of Artiﬁcial Turf - Academic Municipal & Other Tests Aug 2024_tcm18-386957-1.pdf;met-pfas-statement- ﬁeldturf-1 (copy).pdf; 3/17/2025 5:30:28 PM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town Planning Board Members, We do not support the installation of fields made of synthetic turf on the Game Farm Rd site in the town of Ithaca. Such fields pose unacceptable risks and hazards to human health and the wider environment and are not appropriate to our community. The attached August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” "NGO reports." However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to shape the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly on PFAS and microplastics. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. We are also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free, which turned out to be false as reported in the UMass Lowell report. This guarantee by the manufacturer does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests —without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification. This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must first obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to issue Negative Declaration and assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee. Cornell claims that it will carry out “independent” testing in addition to the manufacturer’s “PFAS-free guarantee”, however the testing will be done before the product leaves the manufacturer, and they provide no specifications about methods, thresholds or what will be tested for: eg. TF and/or which specific PFAS. Sincerely, Allison Wilson, Ph.D. and Jonathan Lathan, Ph.D. Bioscience Resource Project Reference: Lowell Center for Sustainable Production, University of Massachusetts Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Academic, Municipal, and Other Testing Efforts. August 2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in-Artificial-Turf-Academic- Municipal-Other-Tests-Aug-2024_tcm18-386957.pdf? rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0. The compilation of PFAS testing from academic, municipal, and independent studies confirms that PFAS have been detected in all components of artificial turf, including turf blades, carpet backing, infill, shock pads, adhesives, and even product packaging. Total fluorine (TF) testing consistently found fluorine across various samples, with concentrations ranging from 16 to 661 µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated coatings, or PFAS-based processing aids. Extractable PFAS tests detected long- and short-chain PFAS in multiple studies, particularly fluorotelomer alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS precursors in adhesives and shock pads. Municipal and nonprofit-led testing further corroborates these findings, with PFAS measured in stormwater runoff, installation materials, and artificial turf fields marketed as ‘PFAS-free.’ These results highlight significant gaps in industry claims and emphasize the need for stricter regulations and improved testing methodologies to assess the full extent of PFAS contamination in artificial turf systems. Allison Wilson, PhD Science Director The Bioscience Resource Project phone: 1 (607) 319 0279 a.wilson@bioscienceresource.org https://www.independentsciencenews.org/ and https://bioscienceresource.org/ and https://www.poisonpapers.org/ Please sign on to our mailing list: https://www.independentsciencenews.org/subscribe/ "Good with Science" PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1 Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts August 2024 A number of organizations have conducted PFAS testing in artificial turf materials. These include academic studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or vendors, sometimes with the assistance of consulting firms. This document provides a compilation of results that have been reported from many of these testing efforts. This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in artificial turf, and for a discussion of key considerations related to test methods. For another recent summary of test results, see the New Jersey Department of Environmental Protection’s Technical Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3 Test results are summarized below for academic studies; regional and municipal studies; nonprofits, community organizations, and journalists; and manufacturers. Testing has been carried out using a variety of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or precision of the methods or results. Academic studies Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and expanded the information available on the presence of PFAS in these materials. Results from these studies are summarized in Table 1. Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm, Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork, bark, and coconut). TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently. The authors explain that “collectively, these results point toward polymeric organofluorine (e.g., fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4 PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2 Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be landfilled or incinerated. Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography- mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb rubber infill. Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf blades to determine the presence of PFAS.6 For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the manufacturing process. Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that “much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing literature. Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." This information further supports the possibility that fluorinated polymers were added to the resin. A TOP assay was performed on four samples including artificial turf and product packaging. Because this testing included both artificial turf and other plastic products, this information is relevant primarily for refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did not have significant changes in concentration after oxidation. This was likely because those samples did not contain substantial quantities of the precursor PFAS that break down into the degradation products that were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and showed a higher concentration of degradation products after oxidation. This suggested that the sample contained higher quantities of the precursors that were measured in the TOP assay. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3 A conclusion of this study was that “these results suggest that much of the total fluorine signals measured in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various plastic products.” In other words, this study further supports the importance of carefully choosing test methods that can accurately characterize PFAS content in artificial turf materials. Table 1. Summary of PFAS testing from academic studies. Source Summary Lauria et al. (2022)4 Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing, carpet blades, and infill. TOTAL FLUORINE • “TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 μg of F/g in backing, filling, and blades, respectively).” • TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic material infills. EXTRACTABLE ORGANIC FLUORINE • Backing: range from <LOD - 145 ng of F/g (ppb) • Infill: range from <LOD - 179 ng of F/g (ppb) • Blades: range from <LOD - 192 ng of F/g (ppb) TARGETED ANALYSIS • Results were reported as the sum of fluorine in a sample. • Backing: <LOD - 0.63 ng of F/g (ppb) • Infill: <LOD - 0.15 ng of F/g (ppb) • Blades: “absent” Zuccaro et al. (2023)5 A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH) in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM). FLUOROTELOMER ALCOHOLS PILOT TEST: • “8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at concentrations of 1.0 and 0.71 ng/μL [ppm], respectively. This translates to 300ng 8:2 FTOH/g artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH were not found to be present in detectable levels.” Whitehead (2023) (dissertation)6 Analyzed PFAS in 27 samples of artificial turf blades using several methods. TOTAL FLUORINE • Measured using particle-induced gamma ray emission (PIGE) spectroscopy. • TF ranged from <LOD to 2.94 µg F/cm2. TARGETED ANALYSIS Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC- MS/MS) PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4 • PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). ORGANIC FLUORINE • Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." TOP ASSAY (four samples only) • “[T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t have significant changes in their sum of PFAS concentrations. The sample which had the highest sum of PFAS concentrations before TOP assay showed a more significant increase in measured concentrations.” • Results suggest that “the concentrations of fluorine measured through PIGE are likely indicative of PFAS which does not undergo transformation” into the compounds measured in the TOP assay. Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Regional and Municipal Studies The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and two adhesives used during the installation of an artificial turf field.7 The analyses included targeted analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both organic and inorganic analytes present in liquids, soils, and wastes."8 PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in the carpet, and lower quantities in other materials. Additional results are summarized in Table 2. The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial grass.”9 The City of Portsmouth later initiated further testing with help from a consulting group. This effort included a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis. The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill, the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are summarized in Table 2. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5 Table 2. Summary of PFAS testing led by regional institutions and municipalities. Source Summary Martha’s Vineyard, MA (2020).7 Laboratory results interpreted by consultants at Tetra Tech Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives used during field construction. TARGETED ANALYSIS “Total PFAS by isotope dilution method” • Detected certain PFAS at concentrations above the method detection limit (MDL) but below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb); Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb). Synthetic Precipitation Leaching Procedure • “Select PFAS compounds were detected in the SPLP analysis that were not detected in the total PFAS analysis.” • “The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L), [shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the [adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are equivalent to ppt.) • “The detection of PFAS compounds in the samples of the synthetic turf components via SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain PFAS compounds that were not extractable via the analytical method utilized for total PFAS analysis (isotope dilution method), but were extractable by the more rigorous SPLP extraction process.” TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY • PFAS were not detected during the pre-oxidation measurements. • The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all sample materials at concentrations above the method detection limit but below the reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g. • “Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill] at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)” • “Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at a concentration of 6.08 ng/g.” This concentration was above the method detection limit but below the reporting limit, yielding an estimated value. TOTAL ORGANIC FLUORINE • “Total organic fluorine was detected in the [carpet] at a calculated concentration of 70 parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting that the total fluorine detected in these samples likely represents primarily organic fluorine. However, because the RL in some cases is close to the detected concentration of total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine was not detected in the sample of the [wood infill] above the RL of 10 ppm.” Additional note from consultant report The consultant noted that there were difficulties in the laboratory’s approach. “The detection limits achieved by the laboratory were elevated because of the limited sample weight utilized during extraction and the dilutions required by the low density sample matrix.” PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6 Portsmouth, NH (2021) initial community testing9 The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center, initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad. An independent laboratory measured total fluorine in these materials. TOTAL FLUORINE • Carpet: TF: 83- 119 ppm • Backing: TF: 16 ppm • Shock pad: TF: 61 ppm • Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total fluorine measurements are typical for plastics that have been manufactured with PFAS- based polymer processing aids – which will leave residues of these PFAS at the part-per- million level on the artificial grass.” 9 Portsmouth, NH (2022) testing initiated by City of Portsmouth. Laboratory results interpreted by consultants at TRC10 Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock pad. Results summarized here show presence of substances only. See full report for concentrations. TARGETED TESTING AND TOP ASSAY PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70 individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope dilution liquid chromatography/dual mass spectrometry” in samples of material. This method is considered a targeted test method. Samples were also oxidized and measured for PFAS precursors. • Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples. • Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].” • Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was also detected in a blank sample). Six PFAS were detected in samples after oxidation. • Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation. NON-TARGETED ANALYSIS “Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were performed on each sample to determine if “other” PFAS were present that were not included in the analysis of the 70 individual PFAS.” • Results were “qualitative estimations of presumptive positives.” Several additional chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl) carbonate, was tentatively identified in the carpet sample. The other chemicals were reported as “unknown.” Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7 Nonprofits, Community Organizations, and Journalists A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial turf. Below are some examples. Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11 The organizations tested backing of both new turf and older, discarded turf. They also tested a number of samples of artificial grass blades (carpet fibers). They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS. They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is a long-chain PFAS that is no longer manufactured in the US due to concerns about health and environmental effects. They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of fluorine that suggest the presence of PFAS.11 Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted samples of new and older turf to commercial and research laboratories for various types of PFAS analyses. Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS- free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS measured after installation were higher than the levels measured before installation. Three other PFAS were also detected in the post-installation stormwater samples (see Table 3). Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8 Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists. Source Summary NONPROFIT AND COMMUNITY ORGANIZATIONS Testing reported in The Intercept (2019).11 Results summarized by New Jersey Department of Environmental Protection.2 Targeted and total fluorine testing conducted on new turf carpet samples; targeted testing conducted on used sample. TARGETED ANALYSIS • New turf carpet sample: 6:2 FTSA: 300 ppt • Used turf carpet sample: PFOS: 190 ppt TOTAL FLUORINE ANALYSIS • New turf carpet blades: 44-255 ppm Woodbridge, CT (2021)12 Samples of stormwater runoff were collected before and after the installation of an artificial turf field from a swale located near the artificial turf field installation site. Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS. TARGETED ANALYSIS of runoff • Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt) • After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L (ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt) Preliminary dermal exposure tests by Public Employees for Environmental Responsibility (PEER)13 Used skin wipes to measure PFAS on four individuals before and after play. Results showed differences in pre- and post-play PFAS levels for artificial turf and grass. Center for Environmental Health (CEH)14,15 CEH tested samples of artificial grass used for residential applications. PFOS was detected during testing. Based on the levels detected, CEH sent California Proposition 65 notices of violation to relevant parties. JOURNALIST Philadelphia Inquirer (2023)16 The Philadelphia Inquirer purchased samples of artificial turf carpet used by Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS. TARGETED ANALYSIS • Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Manufacturers Determining which chemicals are present in a product can be challenging because chemical contents are frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9 manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of two manufacturers that have provided test data. As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was detected above this threshold. Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts consulted by the journalists suggested that the laboratory test results had limited value, in part because of high detection limits.18 In some cases, targeted tests have been used to inform PFAS-free statements. For example, one manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at 100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17 In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term “PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100 ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile products.21) Table 4. Examples of PFAS testing led by manufacturers. Source Summary Artificial turf manufacturer example #1 (2023)17 The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The lowest calibrated detection is at 100 parts per trillion.” TARGETED ANALYSIS OF PFOA AND PFOS • PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect concentrations below 100 ppt. Artificial turf manufacturer example #2 (2022)22 Results summarized by The Philadelphia Inquirer (2024)18 The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI Laboratories Inc. for targeted PFAS testing. TARGETED ANALYSIS • The laboratory’s summary of results stated that “all extractable PFAS compounds were non-detect at a level of 2-4 ug/kg (ppb).”22 • Experts consulted by The Philadelphia Inquirer expressed concerns about the testing methods and the high detection limits used. They noted that lower detection limits and a total organic fluorine test would have yielded results that are more informative.18 Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10 Acknowledgments This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger- Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather Whitehead, PhD. This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection, State of New Jersey. Research for this report was supported by The Heinz Endowments. The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative strategies for communities and workplaces to adopt safer and sustainable practices and products to protect human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions, and government agencies to build healthy work environments, thriving communities, and viable businesses that support a more sustainable world. References 1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18- 385224.pdf (July 2024). 2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023). 3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023). 4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672. 5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols (FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280. 6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant to human health and the environment (dissertation), https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023). 7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report, https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL (February 2021). 8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure, https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024). 9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021, https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new- synthetic-turf-field/ (2021). PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11 10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf, https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf (2022). 11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019, https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October 2019). 12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021., https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021). 13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin, https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024). 14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act: Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document., https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024). 15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024., https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024). 16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed. Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas- forever-chemicals-cancer-20230307.html (2023). 17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp- content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024). 18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial- turf-field-murphy-recreation-20240223.html (23 February 2024). 19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and- artificial-grass/ (2023, accessed 5 June 2024). 20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/. 21. State of California. CA Health & Safety Code § 108945, https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha pter=12.5.&article= (2022). 22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022, https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022). From: To: Subject: Attachments: Sent: Yayoi Koizumi Town Of Ithaca Planning; pbstaﬀ@cityoﬁthaca.org; Correction of Record: Synthetic Turf Fiber Loss & Cornell’s Expansion Plan DTSC 2024 PFAS and Chemical Classes of Concern in Synthetic Turf.pdf;Woelke D March 4 Cornell 4 Mar 2025-2.pdf; 3/18/2025 1:15:55 AM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town of Ithaca Planning Board Members, I am submitting the attached documents prepared by Dianne Woelke for California’s Department of Toxic Substances Control (DTSC). She represents Safe Healthy Playing Fields, a national nonprofit advocating for safer playing surfaces. Cornell University has raised concerns regarding one of her earlier submissions from June for the Meinig Fieldhouse project, specifically stating that her comments about toxic chemicals contained “no specific citations provided” (Agenda Packet, March 4, 2025, p. 171). To address this, I have attached her formal comment submitted to DTSC in September 2024, which includes detailed references to the chemicals listed. Additionally, I would like to clarify that some criticisms of her submission are unwarranted. For example, the claim that her concerns about crumb rubber and infill are “irrelevant” to the Game Farm Road field fails to acknowledge that her original letter was written specifically for the two synthetic turf fields in and adjacent to the Meinig Fieldhouse, which do contain infill. Furthermore, she has since submitted a separate public comment on the Game Farm Road site, which I will also resubmit for the Planning Board’s review. Notably, page 2 of that comment highlights the loss of turf fibers and the heightened microplastic pollution risks associated with field hockey turf blades. I would like to emphasize one critical finding from her submission regarding synthetic turf fiber loss and microplastic pollution: A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its blades annually. This estimate is ten times lower than a previous Danish study (0.8 kg/m²). This equates to 2,000 to 3,000 pounds of microplastic blade loss per year per field. Newer playing fields that do not require infill poured on top of the synthetic carpet are more densely woven, may have double backing, and have the potential for significantly greater microplastic blade and carpet backing loss to the environment. These findings are particularly relevant to the Game Farm Road field, as it does not contain infill but may pose even greater microplastic contamination risks due to its design. Please review the attached materials. Best Regards, Yayoi Koizumi Yayoi Koizumi Zero Waste Ithaca | BYO - US Reduces Founder | Co-Founder zerowasteithaca.org usreduces.org 30 September 2024 To: Dr. Meredith Williams From: Safe Healthy Playing Fields, Inc. Subj:Candidate Chemicals in Artificial Turf Dear Dr. Williams: Thank you for the opportunity to submit these comments on behalf of Safe Healthy Playing Fields, Inc. (SHPFI). SHPFI is an all-volunteer 501-c-3 non-profit organization. We are committed to educating communities, policymakers and elected officials about the health, safety and financial realities of plastic fields versus grass fields and other synthetic surfaces for their parks and schools. Our constituency ranges from concerned individuals to community and civic organizations, legal, healthcare and science professionals, municipal leaders and state legislators. Toxic and carcinogenic chemicals need to be banned from all consumer products.The plastics industry continues to impose risks to human and environmental health while developing more variations of the same class of chemicals, registering untested or inadequately tested chemicals and products and unleashing them on the unsuspecting public.1,2 We must stop reinventing the wheel for every plastic product and act decisively- public and environmental health and safety demand it more now than perhaps ever before. As a major contributor to the triple threat of the climate crisis3, biodiversity loss4 and the tsunami of plastic waste5 that has enveloped the earth, it is imperative CA DTSC/SCP take rapid and decisive action to protect both human and environmental health from this wholly unnecessary toxic plastic product. Failure to take timely and decisive action on toxic chemicals has wrought significant burden globally.Synthetic turf is made of mixed plastics.There are over 16,000 known chemicals found in plastics. Of the known chemicals, 4,200 are considered “highly hazardous” to human and environmental health. Of these 4,200 chemicals, only 980 have been regulated by any global agency and less than one percent can be considered non-hazardous.6 Per- and polyfluoroalkyl substances (PFAS) are but one of the 15 categories of chemicals of concern in plastics. These chemicals add disease burden and health care costs. In the United States (US), for 2018, the attributable cost of plastics to disease and health care related costs was $249 billion; for PFAS alone, it was $22.4 billion.7 The societal cost globally is estimated at $16 trillion USD annually for PFAS clean ups and health care for impacted individuals.8 Whether used indoors or out, all fossil fuel based petrochemical plastic grass carpet products pose unacceptable health risks. So called bio-based plastics do not provide additional benefit.9,10 Used both indoors and out, synthetic grass carpet is found in commercial and residential applications. They are installed in childcare centers, gyms, spas, parks, yards, indoor athletic fields and more. Children and adults play on these surfaces, sometimes on a daily basis, while sports teams are exposed to these plastic carpets often for 2-3 hours/day, 3-6 days/week. The highly toxic mix of chemicals of concern present all of the same toxicological traits and adverse impacts to sub populations that conventional indoor carpets present. Indoor use has a higher risk for inhalation related injury and long term health consequences due to less ventilation in an enclosed space.11,12 Whether indoors or out, Infants and young children bear a larger burden of risk to PFAS and other chemicals in these plastic carpets by virtue of their height and size relative to older children and adults. This fossil fuel based petrochemical plastic product poses a threat to human and environmental health from cradle to grave.Environmental and Social Justice13 (EJ/SJ) communities are impacted by synthetic turf. From fracking14 of oil to petrochemical refining15 to manufacturing of plastic resin pellets in ethane cracker plants,16 to manufacturing of plastic grass carpets and underlayment pads, to the illegal discarding17 of old plastic playing fields or landfilling and closure of landfills18 and SuperFund19 sites, all related activities are often found in overburdened communities. EJ/SJ communities often have a higher proportion of non-native English speakers.20 These communities are often left out of the decision making process.21 RESPONSES TO QUESTIONS POSED IN DRAFT DOCUMENT: Is the following product definition clear and accurate? Definition: Artificial turf is a synthetic material engineered to mimic natural grass. It is made of plastic, blade-like fibers woven into a backing. It would be more accurate to state synthetic turf is a fossil fuel-based petrochemical plastic product engineered to resemble natural living grass. Are there additional chemicals in the blades and backing components not discussed in this document that SCP should evaluate? There are a multitude of toxic and carcinogenic chemicals found in synthetic turf, including, but not limited to: ● Phthalates22-27 ● Latex (including styrene butadiene)28-33 ● Polyvinyl chloride34-36 ● Naptha37-39 ● Siloxanes40,41 ● Talc42,43 ● Di/Isocyanates44-46 ● Formaldehyde47-49 ● Fungicides50-54 ● Flame retardants55-58 ● Coal fly ash59,60 ● Dibutyltin Ethylene glycol61-63 ● Anti-microbials64-66 ● Colorants67,68 ● UV stabilizers69-72 ● Anti-static treatments73-78 Can you provide information about any ongoing environmental toxicological or exposure studies on artificial turf? The Kassotis Lab, Wayne State University, Detroit, MI Endocrine Disrupting Toxicity Associated with Artificial Turf Materials and Use79-81 The Ecology Center, Ann Arbor, MI80,82,8 Dr. Homero Harari,ScD, Assistant Professor in the Department of Environmental Medicine and Public Health at the Icahn School of Medicine at Mount Sinai; exposure scientist in the Senator Frank R. Lautenberg Environmental Health Sciences Laboratory83,84 Netherlands Ministry of Sport85 Department of Civil and Environmental Engineering, Norwegian University of Science and Technology86 Dr. Genoa Warner, PhD. Environmental toxicologist, Endocrine Disrupting and Biological Chemistry Lab; New Jersey Institute of Technology, will be conducting PFAS testing on old synthetic turf samples fall 202487 Public Employees for Environmental Responsibility, Dr. Kyla Bennett, PhD, JD. On going testing for PFAS in synthetic turf88 Dr. Jimena Diaz Leiva, PhD, Former Director, Center for Environmental Health, Oakland, CA (PFOS in synthetic turf)89 Dr. Jaime DeWitt, PhD, Director of Pacific Northwest Center for Translational Environmental Health Research, Oregon State University (PFAS; POPs)90 Dr. Courtney Carrigan, PhD,exposure scientist and environmental epidemiologist (PFAS)91 Dr.Susan Allen, PhD, chair Department of the Environment, Ithaca College (environmental toxicology; PFAS; microplastics; crumb rubber)92 Dr. Leonardo Trasande,Wagner School of Public Service and NYU’s College of Global Public Health (Plastics; Phthalates; PFAS; Endocrine disrupting chemicals; children’s environmental health)93 Dr. Phillip Landrigan, MD MSc;Director of the Program for Global Public Health and the Common Good; Director of the Global Observatory on Planetary Health Schiller Institute for Integrated Science and Society (Global Public Health; Children's Environmental Health; Occupational Health; expert on Plastics)94,95 Dr. Rachel Massey, ScD,Senior Science and Policy Advisor at Collaborative for Health and Environment and Senior Research Associate at the Lowell Center Sustainable Production at the University of Massachusetts Lowell96,97 Dr. Zehnyu Tian, PhD, Assistant Professor in the Department of Chemistry and Chemical Biology, North Eastern University (Environmental chemistry; 6PPD; plastics)98-100 Dr. Graham Peaslee, PhD, Professor Emeritus, Department of Physics & Astronomy,University of Notre Dame101-103 Dr. William DeHaan, PhD, Oceanography, Marine Management; University of Barcelona104-105 Dr. Sarah-Jeanne Royer, PhD, Oceanographer, microplastics. Scripps Institute of Oceanography, La Jolla, CA106,107 Kristen Mello, MSc, analytical chemist (PFAS)108 Dr. Ariane Middel, PhD, engineering. Arizona State University (Tempe); UCLA Luskin Center for Innovation;President of the International Association of Urban Climate (IAUC); Board member of the American Meteorological Society (AMS) Built Environment (BUE), a member of the International Society of Biometeorology (ISB), and the Institute of Electrical and Electronics Engineers (IEEE)109,110 Dr. Win Cowger, PhD, environmental scientist, microplastics. Moore Institute for PlasticPollution Research111,112 Are there any Life Cycle Assessments (LCAs) that evaluate artificial turf in California or U.S. environments? LCAs that have been done have been paid for by parties seeking to install synthetic turf, and like EIRs that are sometimes done under the California Environmental Quality Act (CEQA), are incomplete; do not recognize synthetic turf as an impervious surface that it has been declared by the US EPA; do not consider the contribution of greenhouse gasses (cradle to grave and through complete decomposition) of the plastic carpet and infills; the toxic runoff that occurs; impacts on biodiversity; contribution to climate change; heat island effect; plastic and microplastic pollution for centuries. These reports have used fraudulent chemical testing results done by scientists for hire, false narratives created and perpetuated by industry, false claims regarding community engagement and surveys and been biased towards the plastic that those paying for the studies seek to install. They do not include a cradle to grave analysis, do not fully consider the human health and environmental impacts, the multiple chemical exposures, impact on vulnerable populations and communities, hidden costs associated with maintenance, repair, safety testing, infill replenishment, replacement, removal, disposal as well as costs associated with health care burden and remediation of air, water and soil. The city of Los Angeles will be conducting such a severely limited LCA, reviewing “installation, operation and maintenance for different types of turf surfaces,” which again, is not thorough nor adequate and will not include a full cradle (fossil fuel extraction) to grave (the 1,000 years to fully decompose113) analysis. Chemical Additives To what extent do artificial turf manufacturers or raw material suppliers have influence over the chemical additives in their products? There are multiple companies that manufacture raw materials used in the manufacture of synthetic turf, including international manufacturers. It would seem logical that synthetic turf manufacturers have sole discretion over the materials they purchase for use. Even if participating in a purchasing pool, it would be the responsibility of the parent company to request information on chemical composition and independent third party testing for verification for chemicals of concern in the products they purchase for use in manufacturing. An example of failure to obtain full disclosure took place in Portsmouth, NH in 2019 when a PFAS-Free synthetic turf field was promised to the city, despite pressure from the community and expert testimony that no such product existed.114-117 Synthetic turf manufacturers often use chemical additives that chemical manufacturers will not provide Safety Data Sheets (SDSs) for (eg Dow Chemical) and import yarns and colorants and other components that those manufacturers will not provide chemical information on despite requests. Synthetic turf manufacturers then go on to claim that their products do not contain “intentionally added PFAS.”118-125 Synthetic turf made outside of the US may be imported for sale as well.125-128 Also imported are colorants, infills, antimicrobials, such as Triclosan (trade name Microban), silver nanoparticles additives and more,130-135 Triclosan is registered with the US EPA under the name Microban Additive B and contains 99% 5-Chloro-2-(2.4-dichlorophenoxy) phenol with 1% inert ingredients. It is specifically for use in polymer plastics and latex. Triclosan was banned in the US due to its carcinogenic effects on human skin.136,137 One of the most studied chemicals, triclosan, cannot be completely removed by wastewater treatment plants. It is also found in wastewater effluent and biosolids sold as fertilizer and has been found world wide in freshwater (effluent and surface water) in concentrations ranging from 0.5 ng/L to 14 mg/L. It is an endocrine disruptor, persistent in the environment and bioaccumulative in both non aquatic and aquatic organisms.138 “TCS's [triclosan’s] potential for endocrine disruption, as the antimicrobial has been shown to disrupt thyroid hormone homeostasis and possibly the reproductive axis. Moreover, there is strong evidence that aquatic species such as algae, invertebrates and certain types of fish are much more sensitive to TCS than mammals. TCS is highly toxic to algae and exerts reproductive and developmental effects in some fish. The potential for endocrine disruption and antibiotic cross-resistance highlights the importance of the judicious use of TCS.”139 “Methyl-triclosan presents a greater potential for bioaccumulation than triclosan. Triclosan was detected in all samples, at concentrations (5–27 μg kg−1) comparable to values found in other surface sediments under the influence of marine wastewater outfalls. Its dispersal was closely associated with fine and organic-rich fractions of the sediments. Methyl-triclosan was detected in approximately half of the samples at concentrations <11 μg kg−1. The occurrence of this compound was linked to both wastewater discharges and biological methylation of the parent compound.”140 Triclosan was shown to be toxic to Ampelisca abdita and Americamysis bahia in water only and sediment exposures. The chemical was also shown to accumulate in tissues of these estuary sediment dwelling organisms.141 It was confirmed to be toxic to microalgae in biofilms in a 2014 Swedish study.142 After years of efforts to conceal research showing the toxicity of triclosan and other pollutants on the part of the chemical industry143 and mounting concerns and frustrations over lack of progress towards regulation,144 more than 700 medical professionals, scientists and non profit organizations met in Florence, Italy on 28 Aug 2016 for the 36th International Symposium on Halogenated Persistent Organic Pollutants (DIOXIN).145 More than 200 signatories from 29 countries, including many well known to CA DTSC, developed the Florence Statement on Triclosan and Tricloroban.146,147 On 2 September 2016, the final day of the Symposium in Florence, after many years of waffling, the US FDA issued its final rule, banning triclosan and triclorocarban, leaving the field wide open for additional uses.148 “This final rule applies to consumer antiseptic wash products containing one or more of 19 specific active ingredients, including the most commonly used ingredients – triclosan and triclocarban. These products are intended for use with water, and are rinsed off after use. This rule does not affect consumer hand “sanitizers” or wipes, or antibacterial products used in health care settings.”149 In 2017 a Danish study showed that exposing the copepod Acartia tonsa to microplastics and triclosan was more toxic than microplastic or triclosan exposure alone, demonstrating a clear synergistic effect.150 Wu, Ji, Zahng et al (2018) were able to determine the toxicity and fate of triclosan in wastewater. Using gas chromatography-mass spectrometry (GC–MS) and high resolution gas chromatography-high resolution mass spectrometry (HRGC-HRMS), exposing a matrix of seawater and active chlorine to UV light, triclosan rapidly degraded to tetraclosans and pentaclosans, with the formation of five dioxins, including 2,8-DCDD, 1,2,8-TrCDD, 2,3,7-TrCDD, 1,2,3,8-TeCDD, and 2,3,7,8-TeCDD, were identified and quantified. The most toxic dioxin, 2,3,7,8-TeCDD, was the first to form.151 In a Spanish study on microplastics, published in 2020, the ability of triclosan to adsorb and and desorb from microplastic particles of Low Density Polyethylene (LDPE), polyamide (PA) and polyoxymethylene (POM) to aquatic biota, cyanobacterium Anabaena, showed a significant decrease in growth (LDPE 22.3%; PA 94.6%; POM 81.0%) and chlorophyll content (LDPE 58.4%; PA 95.0%; POM 89.6%). Cyanobacters are significant components of phytoplankton and therefore essential to the food chain.138 A study from China released in 2020 showed that polyhydroxybutyrate (PHB) and triclosan easily desorb from microplastics under physiological conditions. As with the 2020 Spanish study, the researchers find that aquatic organisms that ingest microplastics with adsorbed triclosan can become vectors as the toxic chemical desorbs into tissue, bringing risk to the environment and human health via the food chain.152 It is overwhelmingly clear that because a product is colored green or the industry otherwise greenwashes their advertising and sales pitch, that this product is unsafe to humans and the environment alike. Millions of pounds are poured into and onto plastic grass surfaces annually, exposing children, athletes and wildlife and washed into waterways and the ocean. The burden should not fall on the consumer to ascertain the chemicals hidden behind Confidential Business Information (CBI). Parents and caregivers, rightly or wrongly, have an expectation that if a product is available for purchase, that its safety has been verified. They also, again, rightly or wrongly, have the expectation that information provided by manufacturers, trade organizations and affiliated industries is objective, truthful and based on independent, verifiable research and sources. None of this could be further from the truth as it pertains to the synthetic turf industry. The synthetic turf industry, which is unregulated in any state, and has not self-regulated in 60 years, has no incentive to provide full disclosure of the toxicity of their products. They have developed a pattern of issuing signed affidavits118-125 regarding PFAS and the heavy metal lead with impunity. They have also left requests regarding use of phthalates, the number of fields installed and locations of so called recycling facilities unanswered all while making numerous false claims regarding “eco-friendly,” low maintenance, water saving, ability to drain truly outrageous amounts of rain, ability to cool surface temperatures to safe levels for play- all reportable as greenwashing to the California Office of the Attorney General and the Federal Trade Commission. It does not behoove DTSC to repeat these false claims, as was done in the background document. It is also imperative that DTSC not allow continuation of such practices. Is there additional information on PFASs being intentionally added during the manufacturing of artificial turf? Yes. Independent third party testing consistently shows the addition of PFAS to synthetic turf. Culled from public records, 32 PFAS have been found to date with independent testing: ● D2-N-EtFOSAA ● D3-EtFOSA ● D9-EtFOSE ● 6:2 FTS ● 6:2 FTSA ● 7:3 FTCA ● 8:2 FTOH ● 12C2-4:2 FTS ● 13C2-6:2 FTS ● 13C2-8:2 FTS ● GenX ● D3-MeFOSA ● D3-N-MeFOSAA ● D7-MeFOSE ● MTP ● PFBA ● PFBS ● PFDA ● PFHpA ● PFHxA ● PFHxS ● PFNA ● PFOA ● PFOS ● PFPeA ● PFPrA ● PFTrDA ● PMPA ● PPF Acid ● PTFE ● PVDF ● R-EVE PFOS was found on the hands of young soccer players who played on synthetic turf in a small pilot study in San Diego in the summer of 2023.153 That study is currently being replicated by the Kassotis Lab, Wayne State University with 50 student athletes. On 4 March 2024, and reissued on 10 May 2024, the Center for Environmental Health (CEH), Oakland, CA, issued a 60 day Notice of Intent (NOI) to sue Lowe’s, Home Depot and others under the California Clean Air and Water Act (Prop.65) for PFOS in synthetic turf they sell.154,155 Recent communication with CEH indicates this lawsuit is moving forward. The number of lawsuits involving PFAS and other toxic chemicals in synthetic turf will only grow. Of high significance, a study done by the Kassotis Lab, in conjunction with The Ecology Center (Ann Arbor, MI), “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials”in the October 2024 edition of Environmental Toxicology and Pharmacology, demonstrates not only the cytotoxic effects of chemicals in synthetic turf to endocrine organs and cardiac development and function.77-79 This study also demonstrates the importance of looking at combined chemical exposures associated with a given product. No one is ever exposed to one chemical- certainly not with plastics and definitely not with synthetic turf. “Artificial turf is made of a chemically complex set of materials that release a range of toxics, including volatile organic compounds (VOCs), phthalates, bisphenols, microplastics, metals and more. Although many of these are known endocrine disrupting chemicals, little work has been done to characterize the health effects of most turf components, meaning more research is needed to better understand the potential hazards of exposure to artificial turf.”157 PFAS has been documented to leach from synthetic turf fields and contaminate water.157-168 PFAS contamination is costing billions of dollars to clean up water in California.169-172 The industry and owners of plastic fields and yards should be held accountable and made to pay, not the taxpayer. Polymer processing aids: There are multiple examples of PPAs specifically manufactured for use in synthetic turf: 3M Corporation172-177 *3M Dynamar FX 5922 has been used by the manufacturer FieldTurf. This PPA has now been removed from 3M’s catalog.177 Dow Chemical178-185 PVDF186 The need to stop further PFAS exposure cannot be overstated. PFAS187 can cause multiple reproductive disorders188 (including a 40% decrease in female fertility189; a decrease of 62.3% total sperm count in males190; Crohn’s disease191; breast192, testicular, kidney, prostate193 and liver194 cancers. They cross the blood-brain barrier and are related to Autism Spectrum Disorder196, Attention Deficit Hyperactivity Disorder197, increased deaths from Parkinson’s and Alzheimer’s diseases198; immunological effects199; increased serum cholesterol200; effects on infant birth weights201; impaired glucose metabolism, insulin resistance, dyslipidemia and adiposity in children and adolescents202; thyroid hormone disruption203 (including neonatal) and thyroid cancer204. Because they are bioaccumulative, PFAS exposure can impact multiple generations205. Babies are being born pre-polluted with PFAS206. UV Stabilizers207,208 Flame Retardants209-211 Are side-chain fluorinated polymers or other PFASs besides fluoropolymers intentionally added to artificial turf? Side-chain fluorinated polymers are found in many consumer products.212 Patents and third party independent testing indicate that side-chain fluorinated polymers and other PFAS are added to or leach from synthetic turf.213-221 fluoroelastomers “Preferably, the polyethylene composition comprises a processing aid, for example a fluoroelastomer. In some preferred embodiments, the polyethylene composition comprises at least 0.2% to at most 2.0% by weight of a processing aid, for example a fluoroelastomer, preferably at least 0.5% to at most 1.5% by weight, based on the weight of the polyethylene composition. The properties of final polyethylene composition may be obtained from the final resin (which includes optional polyethylene-based composition C and optional additives), or from the resin prior to addition of any masterbatches (such as polyethylene-based composition C) and/or any additives.”222 acrylates (SynLawn patent)223 urethanes (SynLawn patent)224 silicones225-227 ethoxylates227-230 Is there information on ortho-phthalates being intentionally added during the manufacturing of artificial turf? Phthalates are used extensively in the manufacturing of plastics. They have endocrine disrupting231 as well as neurotoxic232 effects. As plasticizers, they are used in plastic toys, playground equipment, “natural rubber” and tire manufacturing233. Use of phthalate-containing products is choosing to risk impairment of children's I.Q.s, their brains and their overall health. Phthalates are both endocrine disrupting chemicals (like PFAS) and neurotoxins. “Ortho-phthalates are diesters of phthalic acid and are the predominate type of phthalate used in commerce. (For simplicity, we will refer to them as phthalates.) They are high-production-volume chemicals used most often as a plasticizer in polyvinyl chloride (PVC) and other plastics.Phthalates are used in numerous consumer products, including food production materials and packaging; medical supplies and coatings of medicines; flooring, wall coverings, and other home materials; and cosmetics and other personal care products. Approximately 4.9 million metric tons are produced annually worldwide. The highest-production phthalates are di-2-ethylhexyl phthalate (DEHP), diisononyl phthalate (DiNP), butylbenzyl phthalate (BBzP), dibutyl phthalates (DBPs), and diethyl phthalate (DEP).”232 The US EPA has begun the process to ban PVC.234,235 Phthalates are used extensively in the manufacturing of synthetic turf.236-240 Identify state-specific data on the total amount of artificial turf used in California. In a 2024 presentation to CalRecycle, Tarkett Sports reported 850 million square feet of plastic grass carpeting is installed in North America annually, with 45% being for use as sports fields.241 There is no state law requiring tracking and tracing of installations, removals and final (not interim) disposal of plastic playing fields. There is inconsistency in requirements regarding permit applications for installation and/or removal of synthetic turf from city to city and county to county. This is made more complex by the wide variety of settings and agencies that use synthetic turf: ● landfill cover turf242,243 ● Superfund sites244 ● highway embankments ● sports parks ● playgrounds ● residential applications ● commercial applications ● daycare centers ● spas ● balconies ● gyms ● airports (indoors and out)245 ● golf courses and centers ● batting cages ● street verges and medians ● waterway lining246 ● storm drain outlets247,248 Turf reinforcement mats, as used for lining of waterways, storm outlets and high erosion slopes are geotextiles and may be made of polyethylene, polypropylene, PET and may be made from recycled plastics- all of which pose significant risk to the environment via chemical leachate and microplastic degradation.249,250 Additionally, school districts, cities and counties may evade California Environmental Quality Act requirements by i) Not filing required documents via the CEQAnet portal ii) Cherry picking which agencies to report to (not filing with DTSC being one example) iii) Providing false information on project(s) iv) Declaring Mitigated Negative Declaration(s) v) Filing Notice(s) of Exemption Legal recourse becomes a financial burden on taxpayers who seek remedy by filing a lawsuit. The amount of waste artificial turf generates is expected to rise because a growing fraction of turf installations are replacements rather than new fields (Berger 2016). These replacements accounted for an estimated 22% of the 1,200 to 1,300 fields installed in the United States in 2013 and around 50% of the 1,500 fields installed in 2015 (Berger 2016). About 40,000 pounds of turf and 400,000 pounds of infill are used for an average field (STC 2017). There are 3 known surveys on synthetic turf installations in parks and schools: San Diego County (schools; parks; public spaces); 14,237,244 sq feet; 326.842 acres New Jersey, State District 21; 34,484,800 sq ft; 80 acres Maryland - Dec 2021; 24,300,000 sq feet; 557 acres In 2010, the industry reported greater than 6,000 playing fields in the US. In 2017, they reported “Currently, there are between 12,000 and 13,000 synthetic turf sports fields in the U.S., with approximately 1,200 – 1,500 new installations each year.” In their 2020 Industry Market Report, STC (Synthetic Turf Council) claimed from 2017- to June 2020, industry growth of 15 percent and “approximately 265 million square feet of installed turf and 777 million pounds of infill”251…added to the carbon footprint in the US in the span of 2.5 to 3 years. On 12 July 2021, interns in Maryland working on a survey of school and park installations of synthetic turf across the state spoke with a representative from FieldTurf (a Tarkett company and manufacturer of synthetic turf). That individual reported there were 29,700 fields installed in the U.S. (with crumb rubber infill). At 1200 to 1500 new fields installed per year, that would put the current number of fields at approximately 33,300 to 34,200. Information provided by Tarkett in at the CalRecycle Tire Conference 19-20 June 2024241 ● 850 million SQF / year of Artificial Turf installed In North America ● 45% of new installations are “SportTurf” ● 41% of synthetic turf installed globally are replacements Artificial turf may include additional materials, depending on the intended use. Layers of hidden material underneath the surface aid in drainage and provide padding but are not required (Jastifer et al. 2019). Infill material between the blades – most commonly rubber or silica sand – also provides cushioning (Jastifer et al. 2019; STC 2022). Artificial turf is considered impermeable by the US EPA and state of California.252,,253 “...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability.”It further has defined impervious surfaces as…[a]ny surface that prevents or significantly impedes the infiltration of water into the underlying soil. This can include but is not limited to: roads, driveways, parking areas and other areas created using non porous material; buildings, rooftops, structures,artificial turf and compacted gravel or soil.” Compaction, as well as the impervious plastic surface, result in increased runoff. Despite synthetic turf industry claims, laboratory testing is not the same as reality. Synthetic turf is unable to handle the amount of rain that comes with an atmospheric river or bomb cyclone. With 12 atmospheric rivers since December 2022 (Scripps Institute of Oceanography, UC San Diego reports 29), predictions of a coming El Niño, increasing frequency and severity of atmospheric events overall, consideration of synthetic turf is antithetical to environmental responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years on average. “Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into stormwater drains and directly to local waterbodies. As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, runoff is five times that of a forested watershed. Excessive stormwater runoff also increases the potential for flooding.” The industry’s often outrageous claims, of synthetic turf’s ability to drain are not scientifically proven in real life events, such as those we are currently experiencing with atmospheric rivers, bomb cyclones, flooding and landslides.254 Synthetic turf is a contributor to climate change via off gassing of methane, ethylene and carbon dioxide and thereby contributors to climate change,255,256 heat islands and catastrophic events such as atmospheric rivers and bomb cyclones. Always hotter than other impervious surfaces, it also contributes to thermal burns, exertional heat illness, including heat stroke and death, and impacts on wildlife and soil biome. Scripps Institute of Oceanography, University of California San Diego reported 46 total atmospheric rivers257 along the U.S. West Coast, causing disastrous flooding and loss of property and life during the 2022 to 2023 rainy season. With what has now been categorized as a Super El Niño year currently, increasing frequency and severity of atmospheric events overall, consideration of synthetic turf is antithetical to environmental responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years on average. Heat and chemical off gassing: ‘This is a climate damn emergency’ Gov. Gavin Newsom The overheating of densely crowded and overbuilt urban centers258 points to the desperate and unmet need of open natural green spaces if the effects of climate change are to be mitigated. Synthetic turf can readily become much hotter than asphalt, reaching temperatures of 1600F to 1800F (regardless of infill type; higher temperatures when a shock pad is placed under the plastic carpet) and have even reached well in excess of 222.8oF (106oC) Thermal burns on plastic turf have even required hospitalization. At a surface temperature of 118°F a first-degree thermal burn occurs in 15 minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.259 An estimated 9,000 student athletes260 are treated for exertional heat illness each year. The reduced functional level created by heat from synthetic surfaces, even at reasonable ambient temperatures can contribute to injuries due to compromised functional level. As the planet heats up, athletes are increasingly impacted by heat related illness by playing on synthetic surfaces. Deaths among high school football players from heat stroke doubled from 2015 to 2017 when compared to the 5 preceding years. Football players are eleven times more likely to suffer a heat related illness.261 Playing on synthetic turf is a contributing factor. After traumatic injuries and cardiac related events, heat illness is the 3rd leading cause of death among teenage athletes. One of the predisposing factors are prescription drugs for treatment of attention deficit hyperactivity disorder, ADHD, which can be caused by PFAS chemicals found in plastics.197 Phoenix June 2021 Phoenix June 2021 Los Gatos, CA June 2024 Geofill Infill Geofill Infill Used Tire Crumb 117oF ambient air Same field/day/time 105oF ambient air Children are not small adults. They are more readily impacted by heat illness262 due to: ● Heat production – Children have higher metabolic rates than adults which leads to higher production of more heat. ● Body surface area – Younger children absorb more heat because they have a greater body area to body mass ratio. For older children and teens, increased body fat and low fitness levels are contributing factors. ● Blood circulation – Children are less able to cool their body temperature by shunting their blood from their body core to their body surface due to lower cardiac output and smaller blood volume. ● Sweat production – Children produce less sweat per gland and sweat at higher body temperatures than adults. ● Fluid replenishment – Children are less likely to self-regulate hydration if unsupervised. ● Children experiencing heat illness are most likely to present with significant neurological symptoms- from delirium, hallucinations, poor muscle control and unsteady gait, difficulty with speaking or unclear speech to seizures or coma. These symptoms may be readily confused with head trauma, epilepsy or drug overdose. Mortality is high and if a child survives heat stroke, their risk for recurrence of heat illness is increased. Synthetic turf off-gasses both methane and ethylene and continues throughout the night, in ever increasing amounts for the 1,000 years it takes for it to decompose. Methane traps 90% more heat than carbon dioxide and is 21 times more potent. Land based plastics produce 2 times more methane and 76 times more ethylene than plastics found in waterways and oceans.255 The heat islands created by plastic turf playing fields are large enough to be visible from satellites circling our planet.Even if all synthetic turf were removed from California today, the methane would linger in the atmosphere for approximately 12 years, contributing to climate change and sea level rise for hundreds of years after the pollutants have been cleared from the air. UC Davis sports fields Crocker Amazon Soccer Fields, San Francisco Rosemont High School, Rosemont, CA / Minnie & Lovie Ward Rec Center, San Francisco, CA Covering the earth in toxic green plastic is not consistent with the California Climate Adaptation Strategy,263 nature based solutions to the climate crisis,264 and it is counter to the objectives of the State’s Extreme Heat Action Plan.265 Further, the off gassing and leaching of toxic and carcinogenic chemicals from petrochemical synthetic turf continues for centuries after its “useful” life.266 OEHHA is currently conducting an assessment of potential health impacts associated with exposures to chemicals released from artificial turf and crumb rubber (OEHHA 2015) OEHHA’s study, which began in 2015 and is not yet complete and focuses on used tire crumb infill, used in 97% of synthetic turf playing fields. “This study focuses on exposure to crumb rubber infill.”267 Plants and soil biota near artificial turf may also be impacted by Candidate Chemicals leaching out of microplastics from weathered artificial turf blades or backing (Ding et al. 2022; Li 2019). For example, artificial turf blades can release (i.e., leach) ortho-phthalates, metals, and organic compounds when exposed to water (Plesser and Lund 2004). Additionally, off-gassing of volatile [gasses]. The use of shock pads under synthetic carpet must be taken into consideration as well. There is an ever increasing amount of information and research regarding microplastics and chemical leachate into our environment, negatively impacting the soil biome, water and air quality and threatening biodiversity and the food chain. The multiple negative impacts on health and the environment from this product cannot be understated.268-276 End of useful life ● Reuse is more common with artificial turf infill than with the blades and backing (Zandwijk RTS 2022). ● Landfill disposal is a concern because of the large mass of waste involved. The roughly 40,000 pounds of turf and 400,000 pounds of infill used in a single average field (STC 2017) has the potential to leach or off-gas significant quantities of hazardous compounds over time. ● Incineration is another potential form of disposal, but it is problematic because the fluoropolymers in artificial turf can form toxic combustion products (e.g., halogenated benzene and naphthalene compounds) (Myers et al. 2014). Also, incineration only accounts for a small portion of overall waste management in the United States (U.S. EPA 2016b). Less than 6%of plastics are recycled.277 Made of mixed plastics, synthetic turf is not recyclable, not sustainable and is a linear, not a circular, product. A lobbyist for The Synthetic Turf Council gave testimony278 in the California Senate Finance and Governance Committee on 12 July 2023 stating: “One thing we don't want to do is to set a [PFAS] limit that's so low that we can't recycle the products because you're going to have environment--I mean, PFAS is everywhere--so you're going to have environmental PFAS that's out there. We want to still be able to recycle products. We don't want to have a situation where we're no longer able and it has to go to the waste stream instead of be[ing] recycled in some way.” The same lobbyist testified in the California Senate Environmental Quality Committee on 19 June 2024, stating that the largest carpet recycler in Los Angeles cannot recycle synthetic turf. The Trex Company, in a 2022 email, stated they will not accept synthetic turf for use in manufacturing of their composite wood/plastic fencing and decking due to the environmental contamination of the plastic fields. One “recycler” with grandiose claims that it would be able to [mechanically] “recycle” 60k tons of synthetic turf per year (3,000 regulation sized 80k square feet fields; 40,000 pounds for carpet and backing; 400,000 pounds of infill), obtained tax incentives in both PA and CA. They have failed to open a plant in either state, and have never recycled a single old field into a new field in their home country of Denmark. With an estimated 30,000 synthetic turf fields in existence in the U.S., it would take 10 years to recycle the current fields with no new fields brought into the market. When “mechanically” recycled (chopped up, essentially) for use in other products, the toxic and carcinogenic effects are added to the new product, along with additional toxic and carcinogenic chemicals. Downcycling plastics into new products creates new, lesser quality products that are not recyclable. Research (2023)279 from a single northern Scotland recycling facility that accepts 22,680 tonnes of mixed plastic waste annually showed mechanically recycling plastics resulted in the release of up to 3,000,000 pounds of microplastics into the environment in a single year. The implications of this research indicate “…as much as 400,000 tons [800,000,000 pounds]per year in the United States alone, or the equivalent of about 29,000 dump trucks of microplastics.” Three other companies, TenCate280 FieldTurf281 and Target Technologies International, Inc., claim they are shipping chopped up old carpets to Cyclyx in Houston for further processing, then to ExxonMobil in Baytown, TX for “advanced chemical recycling,” where the plant is fraught with millions of dollars in fines for violations. The failed scheme was recently exposed.282,283 When shipped out of state for “advanced chemical recycling” (banned in CA under SB54-Allen, 2022), they contribute to the negative human and environmental health effects of Environmental and Social Justice (EJ/SJ) communities. Landfilling and dumping used rolls also often occurs in EJ/SJ communities. (removed from website after email inquiry) Even the so-called mechanical recycling of this product is unregulated in CA, posing a risk to workers and the environment. In communication with CalRecycle regarding a facility in Lincoln, CA: By statute (Public Resources Code §40194 & 40200(b)(2)), facilities whose primary function is to process wastes that have already been separated for reuse and are not intended for disposal are not included in the definition of a transfer/processing facility and thus not a solid waste facility. Title 14, California Code of Regulations, Section 17402.5(d), lists the activities that are not subject to transfer/processing regulations which include a recycling center that meets certain conditions known as the "Three-Part Test." If a facility fails any of the Three-Part Test, then it would be regulated by the LEA as a solid waste activity. The Three-Part Test provides: 1. An activity shall only receive material that has been separated for reuse prior to receipt. 2. The monthly average of the residual amount of solid waste left after processing the material received at the facility is less than 10 percent by weight. 3. The amount of putrescible wastes in the material is less than 1 percent of the amount of separated reuse material received by weight, and the putrescible wastes shall not cause a nuisance. At present, there is not a state program in place that is designed specifically to manage the recycling of synthetic turf. Therefore, the Three-Part Test is used to determine whether a facility is operating as a solid waste facility or operation or a recycling center. If a site is a Three-Part Test recycling center, the LEA can require the operator to regularly show evidence that the site continues to meet the exclusion requirements. If at any time the LEA determines that the site cannot meet the exclusion requirements, the site would be regulated as a solid waste site.” Communication with the local enforcement agency (LEA) for Placer County284 indicates they do not regulate this facility and that recyclers are excluded from permitting. Lawsuits have been filed in San Francisco Superior Court against ExxonMobil for false recycling claims on 23 September 2024 by the California Office of the Attorney General,285 with a second lawsuit filed in the same court by non-profit organizations Sierra Club. Inc. Surfrider Foundation, Inc., Heal the Bay, INC. and Baykeeper, Inc..286 Failure to regulate recycling of synthetic turf allows the fossil fuel, petrochemical and plastics industry to continue exploiting both people and the environment for profit through continued use additional virgin plastic and toxic chemicals; concealing toxic microplastics in new downcycled products; perpetuation of cradle to grave use of toxic fossil fuel petrochemical plastics; perpetuation of plastic’s impact on climate change, biodiversity loss and centuries of micro- and nano plastic pollution. Once past its “best by” date, this petrochemical product is often resold on CraigsList, FaceBook MarketPlace and Turf Cycle USA287 or is otherwise warehoused or improperly or illegally discarded. San Martin, CA ⬆Pescadero, CA ⬆ Different additives in artificial turf may have different long-term environmental fates (Kwon et al.2017). ● fluoropolymers are not expected to be highly leachable or mobile in the environment (Henry et al. 2018) ● their eventual release from artificial turf is expected to increase over time due to weather exposure and frequency of turf use (Lohmann et al. 2020). ● Fluoropolymer particles degrade into microplastics and have the potential for long-distance environmental transport, *polytetrafluoroethylene (PTFE) in deep-sea arctic sediment (Bergmann et al. 2017). ● Fluoropolymers are not benign. High use fluoropolymers include ethylene propylene (FEP), perfluoroalkoxy alkanes (PFA), ethylene tetrafluoroethylene (ETFE)m polytetrafluoroethylene (PTFE aka Teflon), polyvinylidene fluoride (PVDF), polyvinyl fluoride (PVF), and fluoroelastomers.Like side-chain fluorinated polymers and poly- or perfluoropolyethers, fluoropolymers are polymeric PFAS that emit toxic gasses during production, use and through final disposal and decomposition. They are highly persistent in the environment.288 Microplastic PTFE particles have been found in the Arctic sediment and fish in the Mediterranean Sea.289,290 There is a call for fluoropolymer use to be limited to strictly essential use due to human risk associated with their use. Synthetic turf is not a necessary use by any measure. Ortho-phthalates do leach from products (Plesser and Lund 2004; Prasad 2021), but they are only expected to be persistent under certain environmental conditions Ortho-phthalates pose significant risks to human health:291 ● oxidative stress ● estrogenicity ● antagonism to androgens ● gestational, adult diabetes ● cardiovascular mortality by decreasing testosterone levels in adult men ● infertility ● childhood and adult obesity ● cardiovascular disease ● breast and thyroid cancers ● endometriosis ● lipid and carbohydrate metabolism ● increases in prematurity Ortho-phthalates can also:292 ● impair brain development ● increase risks for learning, attention, behavioral disorders in childhood. ● adverse effects on male reproductive tract development There is a clear mandate for immediate action.293,294 “…chronic exposure to phthalates will adversely influence the endocrine system and functioning of multiple organs, which has negative long-term impacts on the success of pregnancy, child growth and development, and reproductive systems in both young children and adolescents. Several countries have established restrictions and regulations on some types of phthalates; however, we think that more countries should establish constraints or substitute measures for phthalates to reduce health risks.” Microplastics: ● recycling of artificial turf may result in microplastic pollution. ● recycling facilities have developed processes to recycle the plastic blades, backing, and infill of artificial turf (Re-Match 2022; TenCate Grass 2022) plastic recycling facilities may be problematic. ● recycling facilities may be a major source of microplastic pollution in receiving waters, particularly molecules smaller than 10micrometers (Brown et al. 2023). ● workers at plastic recycling facilities may be exposed to microplastics through inhalation (Brown et al. 2023). ● Research in China has demonstrated that microplastics can reach virtually all waterways (Zhang et al. 2018); (microplastic release from artificial turf may have far-reaching effects) ●artificial turf additives travel with microplastics; expected to be related to the chemical structure of these additives(Kwon et al. 2017). Research by the Department of Civil and Environmental Engineering, University of California, Los Angeles, and the Moore Institute for Plastic Pollution Research, Long Beach, found “Children's playgrounds contain more microplastics than other areas in urban parks.”295 In addition to the CA Statewide Microplastics Strategy - Senate Bill No.1263 (Chapter 609, 2018),296 CA DTSC recently announced its intent to add Microplastics to the Candidate Chemicals List.297 Microplastics not only leach chemicals, including PFAS, they adsorb other chemicals and bacteria, posing particular risk to the food chain. Even the best BMPs (Best Management Practices) will capture only a small percentage of the microplastics and virtually none of the PFAS and other toxic chemicals from synthetic turf. Drainage systems are not expensive granulated activated carbon (GAC) filters. In humans, micro- and nano-plastics have been found in:298-307 ● Heart ● Liver and spleen ● Lungs ● Blood ● Placenta (maternal and fetal sides) ● Newborn and adult feces ● Breastmilk ● Brain ● Penis, Testes and semen ● Kidney ● Brain ● Uterus Microplastic blade loss from synthetic turf is estimated at 551-661 pounds per regulations sized playing field per year.308 Microplastic synthetic turf blades have been found in Lake Tahoe (personal email communications with researchers at Tahoe Environmental Research Center (TERC)) and the ocean. In 2021, researchers found that synthetic turf fields in Toronto contribute the 2nd highest amount of microplastics to the environment with only litter contributing a higher amount.309 This makes synthetic turf a major source of PFAS and microplastic pollution that cannot go unaddressed. Lake Tahoe researchers found high levels of polyethylene and polypropylene in the lake and “…recorded plastics concentrations more than three times higher than those sampled using a similar method in the North Atlantic subtropical gyre.”310 Published on 29 June 2023, research by the University of Barcelona311 found: “AT [artificial turf] fibers - composed mainly of polyethylene and polypropylene - can constitute over 15% of the mesoplastics and macroplastics content, suggesting that AT fibers may contribute significantly to plastic pollution. Up to 20,000 fibers a day flowed down through the river, and up to 213,200 fibers per km2 were found floating on the sea surface of nearshore areas. AT, apart from impacting on urban biodiversity, urban runoff, heat island formation, and hazardous chemical leaching, is a major source of plastic pollution to natural aquatic environments.” This research leading to the California Coastal Commission's decision to not allow synthetic turf use in the coastal zone at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not superior to natural grass and is not sustainable. Seabin Foundation’s Ocean Health Lab reported that within the first four months of 2024, it “…recorded 194 artificial plants and 938 artificial grass fibres (> 5mm) captured in Seabins around Sydney Harbour. Shockingly, this represents only 10.27% of what Seabins are capturing daily, and this would equate to approximately 1,992 artificial plants and 9,633 artificial grass fibres captured in all the 32 Seabins in four months, which again, is only a sample of what’s entering the Harbour. This suggests the amount of artificial plants and grass polluting our waterways and the Ocean is much, much higher.”312 The evidence of the negative impact of microplastic pollution on environmental health is equally daunting. From zooplankton, krill and whales to bees, and terrestrial animals of the Americas, macro-, micro- and nanoplastics are impacting aquatic and wildlife, and even our pets. Synthetic turf and microplastics have caused a decrease in bird populations, accumulation of microplastics on bees and negatively impacts ocean habitats and biodiversity both above and below ground. Research from 2021 estimated that >1500 species have ingested microplastics.313 Alternatives to the Candidate Chemicals used as additives a) PFAS i) boron nitride - https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10174278/ https://www.intechopen.com/chapters/81202 https://www.sciencedirect.com/science/article/pii/S0048969723033673 ii) thermoplastic urethane elastomers https://www.osha.gov/isocyanates iii) polyethylene terephthalate (PET) https://pubs.acs.org/doi/10.1021/acs.estlett.1c00559 https://link.springer.com/article/10.1007/s12012-024-09837-6 https://www.sciencedirect.com/science/article/pii/S0160412022001258?via%3Dihub https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9562888/#B242-cancers-14-04637 iv) alteration of engineering processes b) Ortho-Phthalates i) citrate-derived plasticizers https://pubmed.ncbi.nlm.nih.gov/32678732/ ii) polymeric plasticizers https://pubmed.ncbi.nlm.nih.gov/36969097/ iii) coating of surface SHPFI questions any potential use or release into the environment an anticoagulant (blood thinner) for use in non-medical plastic application. iv) terephthalate https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9562888/#B242-cancers-14-04637 https://pubmed.ncbi.nlm.nih.gov/36969097/ v) epoxy https://pubmed.ncbi.nlm.nih.gov/36969097/ https://www.artresin.com/blogs/artresin/how-dangerous-is-your-epoxy-resin#:~:text=Epo xy%20resins%20can%20be%20harmful%20if%20not%20used,as%20environmental%2 0harm%20if%20not%20handled%20with%20care. vi) aliphatic compounds https://dtsc.ca.gov/wp-content/uploads/sites/31/2021/06/HHRA-Note-12-Petroleum-June -2021-A.pdf https://onlinelibrary.wiley.com/doi/10.1002/0471125474.tox049.pub3 vii) benzoate compounds More specificity is needed https://www.ewg.org/news-insights/news/2024/02/what-sodium-benzoate With over 84,000 chemicals in commerce and only 200 having been tested for safety314 and exceptionally few studies that look at combinations of chemicals, despite knowing that even non-toxic chemicals can act synergistically to cause cancer, SHPFI urges DTSC to not up the ante of exposing people and the environment to potential regrettable substitutes. Will swapping out chemicals decrease synthetic turf's impact on climate change? On loss of biodiversity? On the effects of natural transpiration, ground water recharging carbon sequestration and oxygen production? Will these alternative chemicals support a living soil biome so necessary for life on earth? Will they reduce the reliance on fossil-fuels? Will they remove all toxic leachate? Will they reduce microplastics in the environment? In humans, wild and aquatic life? The food chain? Will they reduce plastic production and plastic pollution? SHPFI strongly objects to continuing to use children, other vulnerable populations, EJ/SJ communities and wild and aquatic life, as guinea pigs so that the fossil fuel, petrochemical and plastics industries can continue to profit while ignoring or otherwise greenwashing impacts on human and environmental health. Moving forward to regulation: ● Disclosure of chemical composition and independent third party testing by commercial and/or academic laboratories, using testing standards and testing laboratories designated by CA DTSC must be a requirement under regulation. ● New testing should be required anytime there is a change in formulation in the chemicals procured for and used during or post manufacturing to avoid regrettable substitution of chemical components or testing methods. ● Regulatory requirements must be updated in a timely manner to reflect drinking water standards for PFAS and POPs established by the State and in accordance with current state of independent peer reviewed science, evolving public health goals and technology that allows detection of more toxic chemicals at increasingly lower levels. ● Regulation should require disclosure of CBI and chemical bearing patents. ● Regulation should include a mechanism to track and trace installation, removal and through final disposal. We ask that DTSC work with legislators to ensure this process. ● Regulation of so-called mechanical recycling facilities must occur. DTSC must work with CalRecycle and legislators to ensure this regulation. ● Synthetic turf must be declared hazardous material. Regulation should be reflected in transport into and within the state, as well as transport to landfills and/or out of state. ● Regulation should require notification of all purchasers, owners and users of synthetic turf, whether new, donated or resold. DTSC should work with OEHHA to unsure notification and signage applies in all instances and locations, including state and local agencies, parks and schools ● Regulation should require schools and all fairgrounds and other locations where synthetic turf is installed be included in small municipal Separate Storm Sewer System (MS4) Program to alleviate taxpayer burden for violations under the California and Federal Clean Water Acts. While this does not fall under the purview of DTSC/SCP, we ask that both work in conjunction with the State Water Resources Control Board to better protect Californians right to clean water, air and soil. Only with stringent guardrails can false claims be averted, valid testing results be assured, and human and environmental health be protected. CA DTSC has a duty to immediately restrict low-hanging fruit like artificial turf fields where the science on risk is clear, and the market is replete with vendors of proven alternatives: natural grass fields.We ask that DTSC/SCP expeditiously bring synthetic turf under the strictest regulation possible while working with legislators to ban this unnecessary product. States across the country and in communities up and down California are bringing forth bans, moratoriums and legislation. Regulatory support is urgently needed. 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Accessed 25 Oct 2023. https://iaks.sport/en/news/effective-rainwater-treatment-intercepts-microplastics-artificial- turf 310.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 311. https://www.latimes.com/california/story/2023-07-14/lake-tahoe-troubling-concentrati on-microplastics 312.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 313.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/ 314.Santos, R. G., Machovsky-Capuska, G. E. & Andrades, R. 2021.“Plastic Ingestion as an Evolutionary Trap: Toward a Holistic Understanding.”Science: 373, 56–60. https://pubmed.ncbi.nlm.nih.gov/34210877/ 315.https://www.chemicalsafetyfacts.org/health-and-safety/debunking-the-myths-are-ther e-really-84000-chemicals/ Safe Healthy Playing Fields Inc. www.safehealthyplayingfields.org 4 March 2025: Item #7 - SEQR Discussion, Cornell GFR Hockey Field Support a full environmental review Thank you for the opportunity to submit these comments on behalf of Safe Healthy Playing Fields, Inc (SHPFI). SHFPI is an all-volunteer 501-c-3 non-profit. We are committed to educating communities, policy-makers and elected officials about the health, safety and financial realities of plastic fields versus grass fields and other synthetic surfaces for their parks and schools. Our constituency ranges from concerned individuals to community and civic organizations, legal, healthcare and science professionals, municipal leaders and state legislators. SHPFI is in full support of a GEIS and full SEQR. This project should not be exempt from a full review of environmental impacts. Despite Cornell University’s word that they will not seek to install additional synthetic turf on it’s campus, there is no formal obligation that would require them to stop further installations, except the upcoming New York Carpet EPR Law. They have not demonstrated transparency, full disclosure, nor a commitment to the safety of students, staff and visitors who would be exposed to the toxic and carcinogenic chemicals known to exist in this fossil fuel-based petrochemical plastic product, whether on playing fields or used in landscaping.1,2 A commitment to not use used tire crumb infill is a distraction meant for all to believe it is the only concern related to synthetic turf. Often sourced outside of the US, plant based synthetic turf infills can contain pesticides, PFAS, heavy metals and more. Because they add excess nutrients to soil and water, they have been implicated in increased frequency and severity of toxic algal blooms.3,4 4 Royer, Sarah Jeanne (Jan 2023). Choosing Synthetic Turf Is Choosing Environmental Harm. Letter to Town Council of Glastonbury, CT. Published in Let’s Talk, Talk-Action.org. https://talk-action.org/choosing-synthetic-turf-is-choosing-environmental-harm/ 3 US EPA (1 Feb 2024). Nutrients and Harmful Algal Blooms Research. https://www.epa.gov/water-research/nutrients-and-harmful-algal-blooms-research 2 Kassotis, C (23 Sep 2024). “Endocrine and cardiometabolic toxicity of artificial turf associated materials.” Video of presentation at NYU Langone Health symposium on plastics research. https://www.youtube.com/watch?v=q8MDXyQKnFA 1 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111), 104562. https://doi.org/10.1016/j.etap.2024.104562 Microplastics: A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its blades annually. This estimate is ten times lower than a previous Danish study (0.8 kg/m2). This equates to 2,000 to 3,000 pounds of microplastic blade loss per year per field.5 Newer playing fields that do not require infill poured on top of the synthetic carpet are more densely woven, may have double backing,6 and have the potential for significantly greater microplastic blade and carpet backing loss to the environment. As calculated by the Martha’s Vineyard Conservancy, a single regulation sized plastic playing field is the equivalent of 3.2 million plastic bags, or 42 million plastic straws.7 Microplastic synthetic turf blades have been found in Lake Tahoe, where researchers found high levels of polyethylene and polypropylene in the lake and “…recorded plastics concentrations more than three times higher than those sampled using a similar method in the North Atlantic subtropical gyre.”8,9,10 Synthetic turf fibers have been found in the world’s oceans, ranging from 12 to over 15 percent of the microplastics found, as reported by researchers in Spain, China, Japan, Australia and Canada. Synthetic turf blades represent as much as 25% of microplastics in surface waters.11 This research lead to the California Coastal Commission's decision to not allow synthetic turf at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not superior to natural grass and is not sustainable. 11 De Haan, WP, Quintana, R, Vilas, C, Cózar, A et al (1 Oct 2023).“The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments.” Environmental Pollution; 334, 122094. https://www.sciencedirect.com/science/article/pii/S0269749123010965?via%3Dihub 10 Personal email communication from research staff at Tahoe Environmental Research Center. Lake Tahoe Email 9 Spencer, C (2023). “Lake Tahoe has higher concentration of microplastics than ocean trash heap.” LA Times. https://www.latimes.com/california/story/2023-07-14/lake-tahoe-troubling-concentration-microplastics 8 Schultz, Madison. 2022. “UC Davis Environmental Research Center fundamental at Lake Tahoe.” Sierra Sun. Accessed 26 Oct 2023. https://www.sierrasun.com/news/uc-davis-environmental-research-center-fundamental-at-lake-tahoe/ 7 Doyle, M, Slavin, D, Thomson, R (29 Jan 2019). “Numbers flawed in turf vs. grass debate.” Martha’s Vineyard Times. https://www.mvtimes.com/2019/01/29/numbers-flawed-turf-vs-grass-debate/ 6 TenCate Pivot (2024). Face weght of 120 ounces per yard2, double backing, total weight 147.5 ounces per yard2. https://geosurfaces.com/wp-content/uploads/2024/05/PIVOT_1.5_Spec-1.pdf 5 Hann, S et al (2018). “Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics Emitted by (but not Intentionally Added in) Products.” Eunomia, United Kingdom. https://www.eunomia.co.uk/case_study/measuring-impacts-of-microplastics/ “Section 21080.5(d)(2)(A) of CEQA prohibits the Commission from approving a proposed development if there are feasible alternatives or feasible mitigation measures available that would substantially lessen any significant adverse effect which the activity may have on the environment. For the reasons discussed in this report, the Commission has conditioned the NOID to require design and implementation of Final Revised Project Plans that do not include the installation of artificial turf.”12 Additional loss of microplastics from the backing (approximately 438 pounds/per field annually), exclusive of the underlayment pad and infill.13 Microplastics both leach and adsorb toxic chemicals and bacteria in the environment, putting the food chain at risk. 13 Kole, PJ, Van Belleghem, F, Stoorvogel, JJ, Ragas, A, Löhr, AJ (10 Dec 2023). “Tire granulate on the loose: How much escapes turf? A systematic literature review.” Science of The Total Environment; (903)166221. https://doi.org/10.1016/j.scitotenv.2023.166221 12 California Coastal Commission (13 Dec 2023). “Notice of Impending Development UCS-NOID-0002-23 (Baseball Stadium Turf).” https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf Toxic Chemicals: As outlined in the 27 Aug 2024 presentation by the California Dept. of Toxic Substances Control (DTSC), there are multiple chemical classes of concern in synthetic turf.14 Some of these chemicals include (not comprehensive): ● PFAS15,16,17,18,19 ● Phthalates20,21,22 ● Latex (including styrene butadiene)23,24,25,26 26 Staff writer (3 Jul 2024). “Artificial Turf Fields.” Institute For Climate Change, Environmental Health, and Exposomics. Mt. Sinai ICAHN School of Medicine. Exposomic Research 25 Sick, S (2021). Patent https://patents.justia.com/patent/10968565 24 Sick, S (2017). Patent application https://patents.justia.com/search?q=FLOOR+PAVEMENT+STRUCTURE+WITH+GEL+L 23 Tomarin, SA (1984). Patent https://patents.justia.com/patent/4497853 22 IE DuPont de Nemours (2015). https://patents.justia.com/patent/9017788 21 Safer Consumer Products Program (Aug 2024). “Background Document on Candidate Chemicals in Artificial Turf.” Dept. of Toxic Substances Control, California Environmental Protection Agency. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicals- in-Artificial-Turf.pdf 20 Ryan-Ndegwa, S, Zamani, R, Martins, T (17 Dec 2024). “Exploring the Human Health Impact of Artificial Turf Worldwide: A Systematic Review.” Environ Health Insights; (18),11786302241306291 https://doi.org/10.1177/11786302241306291 19 Multi-organizational fact sheet (2022). “PFAS polymers pose serious health and environmental threats.” https://drive.google.com/file/d/1fJDsNTIPp-YMT_7aQ0TDvTaLg2lB5PMA/view?usp=drivesdk 18 EI DuPont de Nemours (2013) https://patents.justia.com/patent/8568874 17 Dept. of Toxic Substances Control (27 Aug 2024). “Background Document on Candidate Chemicals in Artificial Turf.” California EPA. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicals- in-Artificial-Turf.pdf 16 Woelke, D (Nov 2024). Compilation of PFAS leachate testing from synthetic turf results. PFAS leachate from synthetic turf 15 Glüge, J, Scheringer, M, Cousins, IA, DeWitt, JC et al (30 Oct 2020). “An overview of the uses of per- and polyfluoroalkyl substances (PFAS).” Environ Sci Process Impacts;22(12):2345–2373. https://pmc.ncbi.nlm.nih.gov/articles/PMC7784712/ 14 Dept. of Toxic Substances Control. (27 Aug 2024). California EPA. Presentation Slides ● Polyvinyl chloride27,28,29 ● Naptha18,,30,31 ● Siloxanes32,33 ● Talc34,35 ● Di/Isocyanates36 ● Formaldehyde29 ● Fungicides26 ● Flame retardants26 ● Coal fly ash26 ● Anti-Microbial agents37,38,39 39 Verdú, I, Gonzalez-Pleiter, M, Leganés, F et al (Mar 2021). “Microplastics can act as vector of the biocide triclosan exerting damage to freshwater microalgae.” Chemosphere. https://www.sciencedirect.com/science/article/abs/pii/S0045653520333907 38 Triclosan Fact Sheet. BioMonitoring California. https://biomonitoring.ca.gov/sites/default/files/downloads/TriclosanFactSheet.pdf 37 Dow Chemical (2017). https://patents.justia.com/patent/20190078235 36 Sick, S (2021) patent https://patents.justia.com/patent/11180894 35 Dow Global Technologies, Inc (2008) patent application https://patents.justia.com/patent/20100279032 34 Sick, S (2015) patent https://patents.justia.com/patent/10968565 33 Dow Global Technologies, Inc (2015) patent https://patents.justia.com/patent/9040627 32 Ferreira T, Homem V, Cereceda-Balic F et al (2024). “Are volatile methylsiloxanes in downcycled tire microplastics? Levels and human exposure estimation in synthetic turf football fields.” Environ Sci Pollut Res Int. 10.1007/s11356-024-31832-1 https://link.springer.com/article/10.1007/s11356-024-31832-1 31 Modern Fibers Inc (1984) patent https://patents.justia.com/patent/4617208 30 Sick, S (2017) patent application https://patents.justia.com/patent/8568874 29 Hayes, GE (2010). https://patents.justia.com/patent/7838096 28 J. F. Adolff AG (1977) patent https://patents.justia.com/patent/4007307 27 DOC Sports Surfaces (2008) patent application https://patents.google.com/patent/US7838096B2/en?oq=7838096 ● Dibutyltin Ethylene glycol40 ● UV stabilizers30,41.42 ● Anti-Static Treatments30 ● Colorants All synthetic turf tested by academic institutions and independent third party laboratories using proper methods, techniques and reporting limits have found PFAS in synthetic turf.43,44 Impervious surfacing: Synthetic turf is an impervious, or impermeable, surface, despite what the industry tells you. The US EPA and the State of California are clear on this issue:45 “...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability.” It further has defined impervious surfaces as…[a]ny surface that prevents or significantly impedes the infiltration of water into the underlying soil. This can include but is not limited to: roads, driveways, parking areas and other areas created using non porous material; buildings, rooftops, structures, artificial turf and compacted gravel or soil.” “Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into stormwater drains and directly to local water bodies. As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, runoff is ﬁve times 45 US EPA, MS4 General Permit Appendix A, Definitions, Abbreviations and Acronyms, https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-a-2016-ma-sms4-gp.pdf 44 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of Massachusetts, Lowell. https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2 0Other%20Tests%20Aug%202024_tcm18-386957.pdf 43 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University of Notre Dame. https://doi.org/10.7274/bg257d30j3m 42 Awonaike, B, Lei, YD, Parajulee, A, Wania, F (1 Dec 2021). “Phase partitioning, transport and sources of Benzotriazole Ultraviolet Stabilizers during a runoff event.” Water Research X; (13),100115 https://www.sciencedirect.com/science/article/pii/S2589914721000281#:~:text=High%20levels%20of%20 UV328%20and%20UV234%20were,a%20sink%20than%20a%20source%20of%20BT%2DUVs 41 International Pollutant Elimination Network.“Communications on Recent Research: Recent Research on UV-328 Further Proves its Potential to Undergo Long-Range Transport, Bioaccumulate, and Cause Harm.” https://ipen.org/sites/default/files/documents/ipen-uv328-research-update-v1_2-en.pdf 40 Sick (2017) https://patents.google.com/patent/WO2018122346A1 that of a forested watershed. Excessive stormwater runoﬀ also increases the potential for ﬂooding.” US EPA Impervious Surface Fact Sheet46 As impervious surfaces, accumulation of particulate matter, jet and leaded AVgas fuel from the multiple flight paths that border Cornell’s campus bring even more need for concern. In 2023, Ithaca had 39.5 inches of rainfall and 42.5 inches of snowfall. In 2024, the totals were 36.5 inches and 35.3 inches respectively. Toxic runoff from synthetic turf contributes 27,000 gallons per one inch of rain per acre of plastic.47 One inch of snowfall is roughly equivalent to 13 inches of rain.48 It is abundantly clear that, given the amount of synthetic turf currently installed on Cornell’s campus, that a massive amount of toxic runoff from synthetic fields is contaminating soil, surface, ground and, eventually, the campus and town’s drinking water. 48 NOAA National Severe Storms Laboratory. (n.d.). Winter Weather FAQ. https://www.nssl.noaa.gov/education/svrwx101/winter/faq/ 47 Cotrone, V (undated). “The Role of Trees and Forests in Healthy Watersheds: Managing stormwater, reducing flooding, and improving water quality.” Penn State Extension. https://extension.psu.edu/the-role-of-trees-and-forests-in-healthy-watersheds 46 US EPA (2020). “EnviroAtlas: Fact Sheet, Percent Impervious Area.” https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/ESN/PercentImperviousArea.pdf Greenhouse Gasses: Synthetic turf off-gasses both methane and ethylene49,50 and continues day and night, in ever increasing amounts for the 1,000 years it takes for it to decompose.51 Methane traps 90% more heat than carbon dioxide and is 21 times more potent. Land based plastics produce 2 times more methane and 76 times more ethylene than plastics found in waterways and oceans. The heat islands created by plastic turf playing fields are large enough to be visible from satellites circling our planet. Even if all synthetic turf were removed from Los Angeles today, methane would linger in the atmosphere for approximately 12 years, contributing to climate change and sea level rise for hundreds of years after pollutants have been cleared from the air.52 A 2017 Swedish study of total life cycle emissions on a modeled 7881m2 synthetic field concluded GHG emissions would be 527 tons of CO2e for a ten year use period, exclusive of manufacturing, transport, construction, removal and disposal.53 The Lawrence Berkeley National Laboratory released a report in April 2024 finding that the greenhouse emissions from plastics is four times those emitted by the aviation industry.54 54 Karali, N, Khanna, N, Shah, N (12 Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence Berkeley National Laboratory Publications. https://escholarship.org/uc/item/12s624vf 53 Magnusson, Simon, Mácsik, Josef (July 2017.. Analysis of Energy Use and Emissions of Greenhouse Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf. Resources, Conservation and Recycling Vol. 122, July 2017, Pages 362-372 https://doi.org/10.1016/j.resconrec.2017.03.007 52 National Oceanic and Atmospheric Administration. “Methane.” https://climate.nasa.gov/vital-signs/methane/?intent=121 51 Chamas, A, Moon, H, Zheng, J (3 Feb 2020). “Degradation Rates of Plastics in the Environment.” ACS Sustainable Chemistry & Engineering;(8)9.b https://pubs.acs.org/doi/10.1021/acssuschemeng.9b06635 50 Royer, SJ (12 Nov 2018). Letter to Mayor M Bowser, Washington DC regarding synthetic turf. Letter to Mayor M Bowser 49 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic in the Environment.” PlosOne 13(8): e0200574. https://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0200574&type=printable The resulting impact on climate change from plastics and synthetic turf are contributing factors to increased flood risk and toxic runoff55; toxic exposures during wildfires56,57; and escalating insurance costs due to both.58,59,60 The most profoundly impacted will be those who can least afford the increased burdens. 60 Capani, C (7 May 2024). “Aviva issues flood risk warning as residents turn to artificial lawns.” Insurance Times; United Kingdom. https://www.insurancetimes.co.uk/news/aviva-issues-flood-risk-warning-as-residents-turn-to-artificial-lawn s/1451833.article 59 Sherriff, L (18 Mar 2024). “Climate change is fuelling the US insurance problem.” British Broadcasting Corp. https://www.bbc.com/future/article/20240311-why-climate-change-is-making-the-us-uninsurable 58 Mandel, A, Battiston, S, Monasterolo, I. (5 Feb 2025). “Mapping global financial risks under climate change. Nature, Climate Change. https://doi.org/10.1038/s41558-025-02244-x 57 Staff writer (17 Jan 2025). “Plastic Chemicals in Wildfire Smoke and How to Protect Yourself.” Plastic Soup Coalition. https://www.plasticpollutioncoalition.org/blog/2025/1/17/plastic-chemicals-in-wildfire-smoke-and-how-to-pr otect-yourself 56 Schlanger, Z (15 Jan 2025). “What Happens When a Plastic City Burns.” The Atlantic. https://www.theatlantic.com/science/archive/2025/01/los-angeles-fire-smoke-plastic-toxic/681318/ 55 Simpson, TJ, Francis, RA (Aug 2021). “Artificial lawns exhibit increased runoff and decreased water retention compared to living lawns following controlled rainfall experiments.” Urban Forestry & Urban Greening; (63), 127232 https://www.sciencedirect.com/science/article/abs/pii/S1618866721002570 Not recyclable: Less than 6% of plastics are recycled.61 Made of mixed plastics, synthetic turf is not recyclable, not sustainable and is a linear, not a circular product, and does not meet any definition of sustainability. The synthetic turf industry misrepresents its products when they make claims related to sustainability and environmentally friendliness. It is not enough to use the vernacular of the day. Circular products62 are “…those products that have reduced or completely no need for virgin resources and are designed with the end of their life in mind.” The United Nations defines sustainable development63 as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” The UCLA Sustainability Committee64 notes: “In simplest terms, sustainability is about our children and our grandchildren, and the world we will leave them”. The Rutgers Center for Sustainable Materials65 definition: “Sustainable materials are materials used throughout our consumer and industrial economy that can be produced in required volumes without depleting non-renewable resources and without disrupting the established steady-state equilibrium of the environment and key natural resource systems.” TenCate’s “recycling” facilities: 65 Rutgers University. “What are Sustainable Materials?” Department of Materials Science and Engineering, Center for Sustainable Materials. Accessed 26 Jan 2025. https://mse.rutgers.edu/center-sustainable-materials 64 UCLA Sustainability Committe, quoting UN World Commission on Environment and Development https://www.sustain.ucla.edu/what-is-sustainability/ 63 United Nations (2024). “Sustainable Development Agenda: What is sustainable development?” https://www.un.org/sustainabledevelopment/development-agenda/#1b1981a30bdd8fde2 62 “What is a circular product?” Circular Tayside, United Kingdom. https://circulartayside.co.uk/what-is-a-circular-product-and-business-model/ 61 Dell, J, Enck, J (May 2022). “The Real Truth about the US Plastic Recycling Rate.” Beyond Plastics. https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/62b2238152acae761414d698/1655 841666913/The-Real-Truth-about-the-US-Plastic-Recycling-Rate-2021-Facts-and-Figures-_5-4-22.pdf Louisiana- California- Separate property Leased property R center of image SHPFI urges you to not support Cornell University’s false environmental claims. Demand excellence. Demand a full environmental review. Do not kick the can down the road to future generations to clean up the environmental mess the University knowingly and willfully seeks to impose without full disclosure or transparency. This is your environment, your health that you are putting at risk and imposing on your children, and their children’s children. Respectfully submitted, Diana Conway, President Dianne Woelke MSN, Board Member Safe Healthy Playing Fields, Inc. https://www.safehealthyplayingfields.org SHPFI is an all-volunteer nonprofit 501-c-3 STATE OF NEW YORK SUPREME COURT: COUNTY OF TOMPKINS ZERO WASTE ITHACA, Petitioner v. ITHACA CITY PLANNING & DEVELOPMENT BOARD AND CORNELL UNIVERSITY Respondents Index No.: EF2024-0816 Justice Mark G. Masler REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF VERIFIED AMENDED PETITION Todd D. Ommen Julianne Frey Attorneys for Plaintiff PACE ENVIRONMENTAL LITIGATION CLINIC, INC. 78 North Broadway White Plains, New York 10603 Phone: (914) 422-4343 Fax: (914) 422- 4433 CI2025-03769 Index # : EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 1 of 17 TABLE OF CONTENTS PRELIMINARY STATEMENT ...........................................................................................1 ARGUMENT .........................................................................................................................2 1. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED THE BECAUSE THE ZWI MEMBERS HAVE STANDING TO BRING THIS LAWSUIT ...............................................................................................................2 A. Petitioner Effectively Alleged Injuries Different from Those of The General Public ................................................................................................2 B. Regardless of Whether or Not the Property is Private, There is Still an Ability to Challenge the Planning Board’s SEQRA Decision .......................5 C. ZWI Has Always Had Standing to Bring This Petition .................................6 2. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK REVIEW” AS REQUIRED BY STATUTE, AND THE NEGATIVE DECLARATION IS ARBITRARY AND CAPRICIOUS. ......................................7 A. The Standard of Review Under SEQRA is A Hard Look Review ................7 1. PFAS ...............................................................................................8 2. Microplastic Shedding ....................................................................10 3. Air Emissions and VOCs ................................................................10 B. The Negative Declaration relies on the Respondent’s Future Actions making it Conditional ....................................................................................11 CONCLUSION ......................................................................................................................12 CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT ....................12 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 2 of 17 ii TABLE OF AUTHORITIES Cases Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849 N.Y.S.2d 112 (3d Dep’t 2007) ................................................................................... 3 Cannon v. Murphy, 600 N.Y.S.2d 965 (2d Dep’t 1993) ................................................................................... 11 Elizabeth Street Garden, Inc v. City of New York, 42 N.Y.3d 992 (2024) ...................................................................................................... 2, 7 Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 613 N.Y.S.2d 257 (2d Dep’t 1994) .................................................................................. 11 Heritage Coal. v. City of Ithaca Planning and Dev. Bd., 644 N.Y.S.2d 374 (3d Dep’t 1996) ................................................................................... 4, 5 Jackson v. New York State Urban Dev. Corp., 67 N.Y.2d 400 (1986) ....................................................................................................... 7 Merton v. McNally, 90 N.Y.2d 742 (1995) ....................................................................................................... 11 New York City Coal. for the Preserv. of Gardens v. Giuliani, 666 N.Y.S.2d 918 (1st Dep’t 1998) .................................................................................. 3 Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768 (Sup. Ct. Westchester Cnty. 2001)...................................................... 6 Saratoga Lake Prot. v. Dep’t of Public Works, 846 N.Y.S.2d 786 (3d Dep’t 2007) ................................................................................... 3 Save Pine Bush, Inc. v. Common Council of City of Albany, 13 N.Y.3d 297 (2009) ....................................................................................................... 1 Save the Pine Bush, Inc. v. Town of Guilderland, 168 N.Y.S.3d 561 (3d Dep’t 2022) ................................................................................... 6 Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715 (3d Dep’t 2002) ................................................................................... 4 Seneca Lake Guardian v. New York State Dep’t Env’t Conserv, 216 N.Y.S.3d 78 (3d Dep’t 2024) ..................................................................................... 6 Shapiro v. Torres, 60 N.Y.S.3d 366 (2d Dep’t 2017) ..................................................................................... 2 W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008) ........................................................................... 9, 11 Rules N.Y. CPLR Rule 1025 (McKinney 2000) .............................................................................. 6 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 3 of 17 iii Regulations 6 NYCRR § 617.7(b) .............................................................................................................. 7 N.Y. Env’t Conserv. Law §8-0101 ......................................................................................... 7 N.Y. Env’t Conserv. Law §8-0109 ......................................................................................... 7 N.Y. Env’t Conserv. Law §27-3313 (2) ................................................................................. 9 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 4 of 17 1 PRELIMINARY STATEMENT Petitioner Zero Waste Ithaca (“ZWI”) respectfully submits this Reply memorandum in further support of its Amended Petition challenging Respondent Ithaca Planning and Development Board’s (the “Planning Board”) arbitrary and capricious finding under the State Environmental Quality Review Act (“SEQRA”) that Respondent Cornell University’s (collectively with the Planning Board, “Respondents”) use of artificial turf fields will have no possible significant adverse environmental impact (the “Negative Declaration”). The Planning Board’s failure to order an Environmental Impact Statement (“EIS”) violates SEQRA’s fundamental purpose: investigating and mitigating environmental harm before it occurs. ZWI brings this petition because its members—who regularly work, study, and engage on Cornell's campus and community—will be directly harmed by the disregard for public health and environmental responsibility. Rather than focusing on defending the Negative Declaration on the merits, Respondents initially allege that ZWI has no standing to bring this suit. Respondents first argue that ZWI’s members suffer no particularized harm from the Negative Declaration, but this contention ignores that, unlike the public at large, ZWI’s members rwork, study, and engage with Cornell’s campus every day. ZWI has demonstrated that its members would suffer harm different from that of the general public including the degradation and recreational, environmental and aesthetic interests in nature and green space. Save Pine Bush, Inc. v. Common Council of City of Albany, 13 N.Y.3d 297, 304 (2009). Moreover, ZWI had the ability to bring suit as an unincorporated association, but even if this were a defect, that defect has now been rendered moot by ZWI’s incorporation. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 5 of 17 2 Similarly, Respondents’ assertion of a proper “hard look” review of the potential environmental impacts and the finding of no significant adverse environmental impacts largely ignores the extensive record in this matter. The fact that Respondents can point to a handful of papers or studies that at least in part support their position does not establish that there will be no possibility of any adverse environmental impact, as required by SEQRA. Elizabeth Street Garden, Inc v. City of New York, 42 N.Y.3d 992, 995 (2024). Absent such a showing, where, as here, there is ample research and analysis showing potential impacts, the only legal path was for Respodents to complete an EIS. Citing only a handful of studies—while disregarding a substantial body of research demonstrating potential harm—does not satisfy SEQRA’s “hard look” requirement. ARGUMENT I. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED BECAUSE THE ZWI MEMBERS CAN ESTABLISH STANDING TO BRING THIS LAWSUIT. Respondents assert that Petitioner lacks standing because its members do not suffer an injury different from the general public, that the members cannot access the project site, and ZWI’s unincorporated status at the time the Petition was filed. Each of these contentions fails after review of the record and circumstances of this dispute, as well as developments since the filing of the Petition. A. Petitioner Sufficiently Established Injuries Different from Those of the General Public. To establish standing under SEQRA, a petitioner must demonstrate an environmental injury different from the general public and that the alleged injury falls within the scope of interests being protected by SEQRA. Shapiro v. Torres, 60 N.Y.S.3d 366, 368 (2d Dep’t 2017). CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 6 of 17 3 The offices of ZWI member Emily Jernigan, a Cornell University full-time staff member and Amina Mohamed, a Ph.D. candidate in Ecology and Evolutionary Biology, are located very near the proposed project site. Respondent asserts that their offices, 560 feet and 265 feet away from the project site, respectively, are too far away from the site to establish standing. (NYSCEF Doc. No. 43, pp 11.). Referencing New York City Coal. for the Preserv. of Gardens v. Giuliani, Respondents compare these facts, two community members of a private institution as similar to trespassers who had established a community garden on a vacant lot. 666 N.Y.S.2d 918, 918-19 (1st Dep’t 1998) aff’g 670 N.Y.S.2d 657, 659 (Court dismissed a SEQRA petition on standing grounds as petitioners did not have any legal right to the garden). Ms. Jernigan and Mohamed did not use the field as it is restricted to athletics, and ZWI does not contend that the project site is available to them. But, notwithstanding that the field may be off limits to non-athletes, proximity can still establish standing. As Cornell community members, ZWI members must be in the vicinity for work and study and have an interest in and enjoy the natural environment. That environmental is what is threated by the PFAS, microplastics and other toxins that would be released by the proposed field, as set forth in the Amended Petition. Indeed, proximity established by ZWI’s affiants is well within the range of that found sufficient for SEQRA standing. The Third Department has previously held that proximity within 1,000 feet of a development site can be sufficient to establish. See, Saratoga Lake Prot. v. Dep’t of Public Works, 846 N.Y.S.2d 786, 791 (3d Dep’t 2007) (petitioners demonstrated standing from 1,000 feet of development); Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849 N.Y.S.2d 112, 115 (3d Dep’t 2007) (petitioner alleged an injury differentiated from that of the general public because her residence was 941 feet away from the proposed project and identified an environmental concern arising from that proximity). Ms. Jernigan and Mohamed’s offices are CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 7 of 17 4 located much closer, within 560 and 265 feet of the project site, well within a distance sufficient for standing (NYSCEF Doc. No. 43, memorandum of law in support denying petition at 11). Respondents further argue that even if their offices were not too far removed, the campus has ample green spaces for the Petitioners to enjoy and interact with nature. (NYSCEF Doc. No. 43 at 16-17). But this argument entirely misses the point of SEQRA, which is to protect the site at issue. Ms. Mohamed said she often takes breaks in the area of the field. (NYSCEF Doc. No. 11, affirmation of Amina Mohamed at 2). The existence of other green spaces is simply irrelevant. First, those neighboring green spaces are exactly what would be impacted by the toxins emanating from the field, as multiple studies submitted to Respondents demonstrate. In any event, SEQRA does not permit the degradation of one green space simply because other green spaces may exist nearby. Ms. Mohamed does not allege to take breaks elsewhere; she takes breaks around the project site. (Id.) The area she frequents, close to her office, the subject of this petition – not other green spaces. Respondents correctly state that proximity alone is not always enough to confer standing. Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715, 717-18 (3d Dep’t 2002). However, the matter here is substantially different from Save Our Main St. Bldgs., where the petitioners did not allege any unique environmental injuries. Save Our Main St. Bldgs., 293 A.D.2d at 909 (petitioners alleged increased traffic concerns, one concerned about more traffic for their store on the main street, noise complaints, an aesthetic injury despite the project not being visible as it was on the same side of the street as petitioner’s store, and a petitioner who was concerned about educational walks through a public main street.) Respondents’ reliance on Heritage Coal. v. City of Ithaca Planning and Dev. Bd., to demonstrate as another example of how the appreciation of a building, Cornell’s Sage Hall, was not enough of an injury, is CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 8 of 17 5 misplaced. 644 N.Y.S.2d 374, 376-377 (3d Dep’t 1996) (dismissal of a SEQRA petition based on standing; three educators failed to show how their injury was different from that of the general public.) Heritage Coal. is distinguishable from the present matter because of the goals of SEQRA; “...the diminution of [their] appreciation of Sage Hall and [their] use of it as a teaching tool, is not, without more, within the zone of interest sought to be promoted or protected by either SEQRA…” Id. at 376. In contrast, there can be no question that the environmental injuries alleged here – environmental contamination from PFAS, micro plastics and other toxins – are within the zone of interests of SEQRA. ZWI members demonstrate unique environmental harms congruent with the SEQRA’s aims and further allege a much closer connection to Cornell’s campus than the public at large. See, N.Y. Envtl. Conserv. Law §8-101. Ms. Jernigan and Mohamed, by virtue of their proximity, interests in the natural state of the campus, members of the faculty and staff, and Ms. Mohamed’s breaks in the areas, establish harm greater than that of the general public. B. Regardless of Whether the Property is Private, Petitioner Can Still Challenge The Planning Board’s SEQRA Decision. Respondents’ next argument focuses on the project site functioning as an athletics field that is only accessible to authorized students; therefore, Respondents argue, ZWI members could not have standing for a field they cannot enter the field. NYSCEF Doc. No. 43, 16-17. Case law does not indicate that Petitioners must have access to the site to sustain an injury from a site’s development. It is not and cannot be the law that development on a privately owned site is immune from SEQRA challenges. Indeed, as discussed below, development will often naturally occur on private property, and courts have found proper standing for environmental groups nevertheless. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 9 of 17 6 The Petitioner’s standing should be considered within the entire scope of the facts. The fact that the field may be, in a sense, “private” does not mean that those in proximity cannot have standing. If it were otherwise, nobody would ever have standing to challenge development on private property, which would eviscerate the purpose of SEQRA. To the contrary, the mere fact that a standing witness does not have legal access to a property does not defeat standing. Indeed, recently the Third Department held just that. In Save the Pine Bush, Inc. v. Town of Guilderland, 168 N.Y.S.3d 561, 566 (3d Dep’t 2022), the court held that an environmental group had standing to challenge a development on private property due to the group’s interests in the surrounding environment. See also, Seneca Lake Guardian v. New York State Dep’t of Env’t Conserv., 216 N.Y.S.3d 78, 81 (3d Dep’t 2014) (where the dumping of leachate into a water body not owned by the plaintiff, found successful standing). C. ZWI Has Always Had the Legal Ability to Bring This Petition, and Now Has Been Incorporated. Finally, Respondents’ argument that ZWI lack the capacity to sue was incorrect and, in any event, is now moot, as ZWI is no longer an unincorporated entity. New York does allow unincorporated organizations to bring legal actions, pursuant to the CPLR § 1025, which provides that “[an action] may be brought by or against the president or treasurer of an unincorporated association on behalf of the association in accordance with the provisions of the general associations law.” While Ms. Koizumi, the founder of ZWI, may not be explicitly listed as the organization's “president,” she functions and operates as such, performing the “equivalent functions and responsibilities” of a small grassroots organization by advocating for change and informing the public of potential risks. Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768, 770 (Sup. Ct. Westchester Cnty. 2001) (provides that an unincorporated organization may proceed in a lawsuit if they function like a treasurer or CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 10 of 17 7 president of an organization); see, NYSCEF Doc. No. 18 at pp 5 (demonstrating Ms. Koizumi’s advocacy.) Additionally, the Respondent’s arguments about undertakings are entirely irrelevant, as there has not been a preliminary injunction at this point and the issue of an undertaking is not before the Court. NYSCEF Doc. No. 43 at 20. In all events, the argument is now moot. As of January 27, 2025, ZWI is recognized by New York State as a not-for-profit corporation. (See Affirmation of Yayoi Kozumi, submitted herewith.) II. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK” AS REQUIRED BY STATUTE. A. The Standard of Review Under SEQRA is A Hard Look Review. ZWI will suffer tangible environmental harms from the planning board’s negative declaration that the project will not have any potential adverse environmental impacts. (6 NYCRR § 617.7(b) (emphasis added)). SEQRA aims to “...encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate environmental damage and enhance human and community resources…” N.Y. Envtl. Conserv. Law § 8-0101. To accomplish these goals, applicants must complete an environmental assessment form (EAF) to determine when a longer, more in-depth environmental assessment, an EIS, is necessary. Id. at § 8-0109. The determination of whether to complete an EIS must be based on the agency (here the Planning Board) taking a “hard look” at all potential impacts. A “hard look” review is when “the lead agency [identifies] the relevant areas of environmental concern, [takes] a ‘hard look’ and [makes] a reasoned elaboration’ on the basis for its decision.” Elizabeth Street Garden, 42 N.Y.3d at 994 (2024) (omitting internal quotations); see, Jackson v. New York State Urban Dev. Corp., 67 N.Y.2d 400, 417 (1986.) If, after taking that “hard look,” there are any potential adverse impacts, an EIS is the only permissible next step under SEQRA. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 11 of 17 8 Put another way, where the material before the reviewing agency indicates that there is any potential for a significant impact, the agency cannot rationally determine that the project will not have a significant adverse impact on the environment. Elizabeth Street Garden, 42 N.Y.3d at 994. Respondents assert that the “multiple hours” spent at planning board meetings, reviewing documents, and asking some questions was enough to counter the numerous contradicting information and studies and glaring biases from fact gatherers the planning board relied on. (NYSCEF Doc. No. 43 at 24-25, 21). But the amount of time is not the question here; rather, the question for this Court is whether that record revealed any potential impacts. The quantity of time spent on an issue is not an indication that the Planning Board had a substantive review of possible adverse environmental impacts. The mere fact there were 70 pages of citations to contradictory studies presented to the Planning Board should have triggered an EIS as it indicates – at a minimum – an open question as to environmental impacts. NYSCEF Doc. No. 18 at pp 5 (One organization’s, ZWI’s, submissions to the Planning Board for consideration.) 1. PFAS Respondents have asserted time and time again that the science proving that artificial turf fields is sound, going so far as saying that “[o]ver 100 scientific, peer reviewed, published studies have been performed worldwide evaluating the potential health risks with turf fields that use crumb rubber. We are not aware of any peer reviewed scientific studies that draw an association between adverse health effects and use of crumb rubber.” NYSCEF Dos. No. 43 at 4. It is again repeated that the PFAS concerns are not serious. Id. at 20 (Respondent states that they have “rebutted” the claims). The question of health impacts is certainly relevant, but an EIS is triggered under SEQRA by any significant adverse environmental impact, not just human health CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 12 of 17 9 impacts. Petitioner was not required to prove medical causation to trigger an EIS. Potential environmental impacts were obvious from the submissions to the Planning Board. The bibliography provided to the Planning Board has several relevant studies affirming synthetic turf is a concern. See generally, Bibliography NYSCEF Doc. No. 20. Similarly, though the Respondents have stated that over 100 scientific and peer reviewed studies claim that there are not adverse health effects linked to the use of crumb rubber, Respondents only cite to six. R. 0641-42. While Respondent’s insist that their own submitted documentation proved more compelling to the Planning Board, that PFAS would not be a significant concern, Respondent’s seemed to contradict their statement earlier in their memo that PFAS contamination is pervasive already. NYSCEF Doc. No. 43 at 20, 4 (respondents allege their own material is persuasive enough to the planning board that PFAS concerns are unimportant but suggest in their statement of the facts their summary suggests that because PFAS are already pervasive in the environment the amount from synthetic turf won’t be significant). Arguing that contamination is already present should not and does not establish no possible environmental impacts. Respondents also assert that because they modified their project to comply with a new New York state ban on carpet containing PFAS, including synthetic turf, going into effect in 2026, the Planning Board was entitled to defer to Cornell’s compliance with applicable law when issuing a negative declaration. N.Y. Env’t Conserv. Law §27-3313 (2). However, the ban going into effect is further evidence that the Planning Board’s negative declaration decision was arbitrary and capricious; environmental risks are associated, which is why there is a ban going into effect in the near future. Id. There is a recognized environmental threat substantial enough to warrant a statewide ban, this should not be ignored under SEQRA. Likewise, the case law Respondents rely on to ameliorate concerns hinges on having already completed a CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 13 of 17 10 comprehensive EIS. W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008). This is all Petitioner here seeks: completion of an EIS to examine these open issues. 2. Microplastic Shedding Respondents assert that they have “submitted extensive documentation from scientific studies” about microplastics. NYSCEF Doc. No. 43. at p. 21. However, this is misleading as the record indicates that one letter, from the Respondent’s employee Dr. Frank Rossi, addressed microplastics. R. 0622-23. The content of Dr. Rossi’s letter focused primarily on the necessity of a synthetic turf field and the alleged adequacy of a microplastic filter. Id. The letter only referenced one scientific study, and it did not name it. Id. This one reference without citing a relevant study is in stark contrast from the alleged extensive documentation. ZWI submitted several studies from credible environmental journals and other sources explaining the risks of microplastics entering the environment. NYSCEF Doc. No. 20 at 33. ZWI submitted information from at least two scientific studies, Chand et al., 2024 and Park et al., 2022, demonstrating that the proposed stormwater filter, added to mitigate plastic pollution in runoff, would not be sufficient as the plastic degrades and becomes smaller than the 212-micron pore size of the filter, leading to plastic pollution and contamination in waterways. R. 1425. In this same vein, the EPA in 2024 documented that the majority of people who had used synthetic turf fields would have find the fill on their person, in their cars and in their homes after the fact (R.1700) demonstrating the difficulty and confirming that synthetic turf users routinely carry microplastics on their skin, shoes, and clothing, dispersing them into homes, cars, and water systems. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 14 of 17 11 3. Air Emissions and VOCs Despite the Respondent’s contentions, the record lacks scientific studies showing a consensus that emissions and VOCs from synthetic turf fields have no health impacts. Initially, as noted above, Petitioner was not required to show health impacts – rather, environmental impacts are the question. In any event, Respondents cite to a 2018 Guidance Document from the New York State Department of Health quoting that the exposures to VOCs, SVOCs and airborne particulate matter was insignificant and not unlike the exposure a person would have on a natural turf field. NYSCEF Doc. No. 43 at 21-22. Respondents failed to include the part of the quote that says when the synthetic field is not exposed to open air, when “collected from an indoor synthetic turf field [air samples] had higher concentrations [of VOCs, SVOCs and airborne particulate matter] than the outside fields.” R. 3152. The earlier 2018 study in complete context corroborates the recent findings from a 2023, among many others, that microplastic inhalation is a confined indoor space is an elevated risk due to microplastic’s small size and density compounded with their ability to stay in the space due to a lack of air circulation. R.1426. ZWI raised several other concerns about air borne microplastics and environmentally persistent free radicals from reputable academic sources, the Center for International Environmental Law and Huang et al., 2022, that went unaddressed. Id. B. The Negative Declaration relies on the Respondent’s Future Actions making it Conditional The insufficient detail provided in the negative declaration reasoning, despite the variety of potential environmental impacts, means the Planning Board's issuance of the negative declaration violated SEQRA. See, Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 613 N.Y.S.2d 257, 259 (2d Dept 1994); Cannon v. Murphy, 600 N.Y.S.2d 965, 968 (2d Dept 1993). CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 15 of 17 12 The Planning Board's reliance on future actions and mitigation measures as justification for foregoing an EIS is impermissible. The cases the Respondents point to, W. Beekmantown Neigh. Ass’n Inc and Merton v. McNally, are fundamentally different in the extent of their mitigation. W. Beekmantown Neigh. Ass’n Inc, 861 N.Y.S.2d at 866 (mitigation after an EIS had already been done did not require another EIS); Merton v. McNally, 90 N.Y.2d 742, 755 (1995) (mitigation entailed adding an additional 2 feet of buffer space). Ultimately the planning board’s decision was not merely arbitrary and capricious given the record but also patently wrong about the facts. It is established that it is not for this Court to determine the whether the planning board’s reasoning for a negative declaration is adequate, it is within the scope to determine if it complied with SEQRA requirements in finding no potential significant impact. Here, due to its failure to adequately assess key issues in the record, the Planning Board plainly did not comply. CONCLUSION For the reasons outlined above, Petitioners respectfully request that this court maintain allow our petition to go forward. Dated: February 13, 2025 White Plains, NY Respectfully submitted, _________________________ Todd D. Ommen Pace Environmental Litigation Clinic, Inc. 78 North Broadway White Plains, NY 10603 (914) 422-4343 tommen@law.pace.edu CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 16 of 17 13 CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT The undersigned attorney hereby certifies: This document complies with the word count limitations pursuant to Rule 202.8-b (c) of the Uniform Civil Rules for the Supreme Court and the County Court as amended by the Administrative Order 270-20, effective February 1, 2021. According to the word processing system used in this office, this document, exclusive of the sections excluded by Rule 202.8-b (b), contains 3,595 words. Dated: February 13, 2025 _____________________________ Todd D. Ommen CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 17 of 17 From: To: Cc: Subject: Sent: Sheila Out Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org Field Hockey Turf on Game Farm Road Site 3/17/2025 1:56:07 PM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Planning Board Members, I'm an Ithaca resident who has grave concerns about this and related projects. One of my concerns is the danger of the microplastics that will result from these projects. I strongly urge you to require a GEIS for the entire Game Farm Road site. Sincerely, Sheila Out 247 Valley Rd Ithaca From: To: Cc: Subject: Sent: **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Larri Richmond Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org; info@zerowasteithaca.org; Field turf 3/17/2025 7:50:17 PM Dear Town Planning Board Members, The August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification.This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee.Additionally, I want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment.Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Larri Richmond 1139 Ellis Hollow Rd. Ithaca, NY 14850 References: 1. Lowell Center for Sustainable Production, University of Massachusetts Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Academic, Municipal, and Other Testing Efforts. August 2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in- Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18-386957.pdf? rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0. The compilation of PFAS testing from academic, municipal, and independent studies confirms that PFAS have been detected in all components of artificial turf, including turf blades, carpet backing, infill, shock pads, adhesives, and even product packaging. Total fluorine (TF) testing consistently found fluorine across various samples, with concentrations ranging from 16 to 661 µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated coatings, or PFAS-based processing aids. Extractable PFAS tests detected long- and short- chain PFAS in multiple studies, particularly fluorotelomer alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS precursors in adhesives and shock pads. Municipal and nonprofit-led testing further corroborates these findings, with PFAS measured in stormwater runoff, installation materials, and artificial turf fields marketed as ‘PFAS-free.’ These results highlight significant gaps in industry claims and emphasize the need for stricter regulations and improved testing methodologies to assess the full extent of PFAS contamination in artificial turf systems. 2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth, NH. October 22, 2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas-statement- fieldturf-1.pdf A supplier for FieldTurf/Tarkett Sports claims that their artificial turf filaments/fibers are fluorine-free and do not contain PFAS, including PFOS, based on manufacturing consistency and compliance with REACH regulations. However, the declaration lacks total fluorine testing, does not specify PFAS detection limits, and does not test the full turf system, meaning polymeric PFAS or precursors could still be present. Additionally, there is no independent third-party verification, making the PFAS-free claim scientifically weak and incomplete. 3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Zero Waste Ithaca Bibliography. Updated March 16, 2025 https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM- s_4bfbmO26R-Q/edit?usp=sharing From: To: Cc: Subject: Sent: Regi Teasley Town Of Ithaca Planning; Conservation Board; Regi Teasley Leopold’s lesson for us 3/13/2025 11:57:41 AM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Good People, In order to respond to the continuing degradation of our Earth: the biosphere in which we live, we must be able to reconceptualize our relationship with Nature. Otherwise we keep making the same mistakes that jeopardize all species, including ours. Thank you for thinking deeply about this. Regi Teasley Ithaca, NY ___________ Protect what is left, recover what is lost of the fair earth. William Morris, “Art and the Beauty of the Earth.” 1881 Subject: Misrepresentation of Injury Data in Cornell’s Synthetic Turf Submissions Dear Town Planning Board Members, Gould et al.’s 2022 study regarding injury rates on artificial turf versus natural grass appears on page 9 in the July 2024 “Additional Materials” submitted to the City and Town of Ithaca Planning Board. The document states: “this article has been responded to previously within these materials.” Upon reviewing the earlier April 2024 “Additional Materials,” I found no additional mentions of Gould. This discrepancy seems to suggest that Cornell University is misrepresenting their own submissions. Cornell again references this study on page 8 of their February 21 supplemental materials submission, as seen below, presenting a misleading interpretation of its findings. Cornell asserts that overall injury rates between synthetic and natural turf are similar, and downplays key conclusions that highlight significant safety concerns associated with artificial turf, particularly in relation to foot and ankle injuries. Gould et al. (2022) conducted a systematic review of 53 studies published between 1972 and 2020. The study unequivocally found that foot and ankle injuries occur at a higher rate on artificial turf—both old and new generations—compared to natural grass. By emphasizing that "overall injury rates" are similar while neglecting the significant differences in foot and ankle injuries, Cornell misleads the reader. Furthermore, while knee injury rates were generally comparable, elite-level football players were more likely to sustain knee injuries on artificial turf. Furthermore, importantly, the study noted that all research claiming a higher injury rate on natural grass was industry-funded, raising concerns about bias. Cornell’s summary strategically downplays these critical findings, failing to acknowledge the study’s strong conclusions regarding increased injury risks. Instead, it shifts focus to adherence to “international safety standards,” which are not the subject of the study and do not negate the evidence of elevated injury risks. It is crucial that Cornell provides an honest and complete representation of the scientific literature rather than selectively framing research to justify synthetic turf installation. The safety risks highlighted in Gould et al. (2022) warrant serious reconsideration of synthetic turf use, particularly given the well-documented biomechanical disadvantages of artificial surfaces, such as increased rotational stiffness and frictional forces that contribute to injury. A responsible approach would be to prioritize athlete safety by acknowledging the full scope of scientific findings rather than distorting them to fit a predetermined agenda. I have attached the full Gould et al. (2022) article to the bibliography. Planning Board members are encouraged to consult the study directly and determine for themselves who is accurately representing the truth. Sincerely, Jill Kellner Reference: Gould HP, Lostetter SJ, Samuelson ER, Guyton GP. “Lower Extremity Injury Rates on Artificial Turf Versus Natural Grass Playing Surfaces: A Systematic Review.” The American Journal of Sports Medicine. May 20, 2022. https://doi.org/10.1177/03635465211069562 Lower Extremity Injury Rates on Artificial Turf Versus Natural Grass Playing Surfaces A Systematic Review Heath P. Gould,*MD , Stephen J. Lostetter,y Eric R. Samuelson,z MS, and Gregory P. Guyton,*§MD Investigation performed at MedStar Union Memorial Hospital, Baltimore, Maryland, USA Background:No study has provided a comprehensive systematic review of sports injuries on artificial turf versus natural grass. Purpose:To comprehensively examine the risk of overall injuries and multiple types of lower extremity injuries across all sports, all levels of competition, and on both old-generation and new-generation artificial turf. Study Design:Systematic review; Level of evidence, 3. Methods:A systematic review of the English-language literature was performed according to PRISMA (Preferred Reporting Items for Systematic Reviews and Meta-Analyses) guidelines. All included articles compared overall injury rates or lower extremity (hip, knee, or foot and ankle) injury rates on artificial turf and natural grass. All sports, levels of competition, and turf types were included. Studies were excluded if they did not include overall injury rates or lower extremity injury rates. Because of the hetero- geneity of the included studies, no attempt was made to aggregate risk ratios to conduct a quantitative meta-analysis. Results:A total of 53 articles published between 1972 and 2020 were identified for study inclusion. Most studies on new-gen- eration turf (13/18 articles) found similar overall injury rates between playing surfaces. When individual anatomic injury locations were analyzed, the greatest proportion of articles reported a higher foot and ankle injury rate on artificial turf compared with nat- ural grass, both with old-generation (3/4 articles) and new-generation (9/19 articles) turf. Similar knee and hip injury rates were reported between playing surfaces for soccer athletes on new-generation turf, but football players, particularly those at high levels of competition, were more likely to sustain a knee injury on artificial turf than on natural grass. Conclusion:The available body of literature suggests a higher rate of foot and ankle injuries on artificial turf, both old-generation and new-generation turf, compared with natural grass. High-quality studies also suggest that the rates of knee injuries and hip injuries are similar between playing surfaces, although elite-level football athletes may be more predisposed to knee injuries on artificial turf compared with natural grass. Only a few articles in the literature reported a higher overall injury rate on natural grass compared with artificial turf, and all of these studies received financial support from the artificial turf industry. Keywords:artificial turf; natural grass; playing surfaces; injury risk; football; soccer Since the installation of the first synthetic turf playing sur- face in 1966 at the Astrodome in Houston, Texas, artificial turf has emerged as a common alternative to natural grass at all levels of competition, from youth to professional. Compared with natural grass, artificial turf offers several potential advantages in terms of cost, durability, mainte- nance requirements, and multipurpose use.14 However, concerns about athlete safety on artificial turf were raised as early as the 1970s, with the first reports of higher injury rates on artificial turf playing surfaces compared with nat- ural grass.1,5 Biomechanical evidence pertaining to the shoe-surface interface and foot-loading patterns has pro- vided further support for concerns about artificial turf from a player health perspective.31 Mechanical properties such as peak torque and rotational stiffness are thought to be substantially higher on artificial turf compared with natural grass, potentially leading to increased fric- tional forces between the foot and the playing surface that could predispose athletes to a higher risk of inju- ries.6,9,29 Moreover, higher relative loads on the central forefoot and lesser toe areas on artificial turf have been demonstrated to cause greater foot inversion, which could potentially result in lateral ankle ligament injuries.11,16,33 5-in-5 M The American Journal of Sports Medicine 2023;51(6):1615–1621 DOI: 10.1177/03635465211069562 2022 The Author(s) 1615 Team Physician’s Corner However, the heterogeneity of study designs in the clini- cal literature has made it difficult to draw definitive conclu- sions with regard to the safety of artificial turf. Previous review articles on overall injury rates,7,10,28,31,32 sport-spe- cific injury rates,25,30 and injury rates for a specific diagnosis, such as a concussion21 or anterior cruciate ligament rup- ture,4 are narrow in scope or narrative in format (nonsystem- atic). Given the presence of multiuse playing surfaces at the youth, high school, and collegiate levels, a more comprehen- sive overview of the literature may provide valuable informa- tion for sports medicine care providers and to athletic administrators. We are not aware of any systematic review that has examined comparative injury rates between artifi- cial turf and natural grass including all sports, all levels of competition, and both old- and new-generation artificial turf types for a wide range of musculoskeletal diagnoses. The objective of the present study was to conduct a sys- tematic review comprehensively examining the compara- tive risk of lower extremity injuries on artificial turf and natural grass playing surfaces. It was not possible to aggregate risk ratios to conduct a quantitative meta- analysis because of the heterogeneity of the included stud- ies with regard to sport, level of competition, artificial turf type, injury setting (ie, practice, game), and how injury incidence was reported. We performed a qualitative analy- sis of the literature on the overall injury risk and the risk of injuries to the foot and ankle, knee, and hip on artificial turf versus natural grass across all sports, levels of compe- tition, injury settings, and types of artificial turf. METHODS This systematic review was performed according to PRISMA (Preferred Reporting Items for Systematic Reviews and Meta-Analyses) guidelines (Figure 1).19 A health sciences librarian developed the search strategy uti- lizing a combination of keywords and database-specific subject headings related to each concept including turf, grass, and injury. A search was conducted within PubMed, Embase (via Ovid), Web of Science Core Collection, and SPORTDiscus (via EBSCOhost) from inception to August 12, 2020. No limit regarding the year of publication was imposed. Non-English and nonhuman studies were excluded from the search, and duplicates were removed using EndNote X9 (Clarivate Analytics). Articles were assessed for study eligibility by 2 reviewers, each of whom was blinded to the inclusion/exclu- sion decisions made by the other reviewer. The 2 reviewers, a senior orthopaedic surgery resident (H.P.G.) and an academic foot and ankle orthopaedic surgeon (G.P.G.), developed an algorithm for initial article screening, oversaw implementation with a team of premedical and medical stu- dents, and performed a detailed review of all included articles. In cases of a disagreement between the 2 reviewers, blinding was removed, and the eligibility of the article was determined by a group consensus, with the senior author (G.P.G.) making the final decision. Studies were included if they compared artificial turf and natural grass playing surfaces with regard to the rate of overall injuries or any type of lower extremity injuries, such as the hip, thigh, knee, lower leg, ankle, or foot. Pediatric and adult studies were included. Studies that reported only upper extremity, chest, abdomen, spine, or concussion injury rates were excluded. Only original research studies were included. Studies that reported only injury rates on artificial turf or natural grass without a direct comparison between the 2 playing surfaces were excluded. All abstracts and full-text Figure 1.PRISMA (Preferred Reporting Items for Systematic Reviews and Meta-Analyses) diagram showing the identifica- tion of included studies. §Address correspondence to Gregory P. Guyton, MD, c/o Lyn Jones, MA, ELS, Department of Orthopaedic Surgery, MedStar Union Memorial Hospital, 3333 North Calvert Street, Suite 400, Baltimore, MD 21218, USA (email lyn.m.jones@medstar.net). *Department of Orthopaedic Surgery, MedStar Union Memorial Hospital, Baltimore, Maryland, USA. yMassachusetts Institute of Technology, Cambridge, Massachusetts, USA. zGeorgetown University School of Medicine, Washington, District of Columbia, USA. Submitted July 21, 2021; accepted November 9, 2021. One or more of the authors has declared the following potential conflict of interest or source of funding: G.P.G. has received royalties and payments for services other than consulting from Wright Medical Technology, consulting fees from Paragon 28, and hospitality payments from Supreme Orthopedic Sys- tems. AOSSM checks author disclosures against the Open Payments Database (OPD). AOSSM has not conducted an independent investigation on the OPD and disclaims any liability or responsibility relating thereto. 1616 Gould et al The American Journal of Sports Medicine articles were stored in Rayyan QCRI,22 which allowed blind- ing of each independent reviewer to the inclusion/exclusion decisions made by the other reviewer throughout the article assessment process. Articles that met the eligibility criteria underwent data extraction for study design (prospective, retrospective, ran- domized controlled trial, cohort, case-control), level of evi- dence (1-5), cohort selection process (ad hoc, systematic), sport (football, soccer, other), level of competition (profes- sional, amateur), injury setting (practice, game, practice and game), number of athletic seasons, and turf type (old generation, new generation, not reported). Specific injury information was also extracted from each article, including athlete exposures, number of practices/games, number of injuries, injury diagnoses, and injury mechanisms. Study funding sources were also considered. Articles that did not state the level of evidence were independently graded for level of evidence by the same 2 blinded reviewers. Level 1 articles included high-quality randomized controlled trials, level 2 articles included lower quality randomized controlled trials and prospective cohort studies, and level 3 articles included retrospective cohort and case-control studies. Studies that did not exclude eligi- ble athletes and used predefined enrollment criteria (eg, entire division, entire conference, entire league) were clas- sified as using systematic cohort selection. Studies were classified as using ad hoc cohort selection if the study excluded some eligible athletes and if the participants were not enrolled according to predefined criteria (eg, ath- letes from several teams were included, but there was no stated rationale for inclusion). Articles were defined as industry funded if the authors received financial support for the research from a company that produces, sells, or distributes artificial turf. RESULTS Characteristics of Included Studies Details of the literature search strategy are summarized in Figure 1. A total of 53 studies met inclusion criteria (see Appendix). Article publication dates ranged from 1972 to 2020. Of the 53 studies, 33 (62.3%) were prospective, and 20 (37.7%) were retrospective. The most common study design was cohort studies (n = 36; 67.9%), followed by case- control studies (n = 15; 28.3%). Randomized controlled trials accounted for only 2 (3.8%) of the included studies. All stud- ies were rated level of evidence 3, with almost all articles classified as either level 2 or 3 (n = 51; 96.2%) (Figure 2). The 3 (5.7%) industry-funded studies were published by the same author with research funding from 1 artificial turf company (Figure 3). Systematic cohort selection was used in 21 studies (39.6%), and ad hoc cohort selection was used in 32 studies (60.4%). A total of 24 articles (45.3%) examined football, 22 articles (41.5%) studied soccer, and 1 article (1.9%) studied both football and soccer. Rugby (n = 4; 7.5%), ultimate Fris- bee (n = 1; 1.9%), and field hockey (n = 1; 1.9%) comprised the remaining 6 articles (Figure 4). Competition level was divided equally between profes- sional (n = 24; 45.3%) and amateur (n = 29; 54.7%) (Figure 5). Figure 2.Diagram showing the conclusion of each article with regard to injury rates on artificial turf and natural grass, with articles classified by level of evidence. Figure 3.Diagram showing the conclusion of each article with regard to injury rates on artificial turf and natural grass, with articles classified by industry funding status. Figure 4.Diagram showing the conclusion of each article with regard to injury rates on artificial turf and natural grass, with articles classified by sport. AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1617 The included studies were evenly split between those that examined both games and practices (n = 27; 50.9%) and those that examined only games (n = 25; 47.2%), whereas the 1 remaining study (1.9%) examined only prac- tices. The included studies tracked injury data over a median of 3 seasons (interquartile range, 1-5). A total of 29 articles (54.7%) reported on new-generation artificial turf, 14 articles (26.4%) reported on old-generation artifi- cial turf, and 10 articles (18.9%) did not report the type of artificial turf (Figure 6). Overall Injury Rate Of the 32 articles that compared overall injury rates on artificial turf and natural grass, over half (17/32; 53.1%) reported no difference in overall injury rates between the 2 playing surfaces, 12 (37.5%) reported a higher overall injury rate on artificial turf, and 3 (9.4%) reported a higher overall injury rate on natural grass. Although 6 of 8 articles (75.0%) that examined overall injury rates on old-generation turf reported a higher risk of injuries on artificial turf, 13 of 18 articles (72.2%) that examined over- all injury rates on new-generation turf reported no difference between playing surfaces. A higher overall injury rate on natural grass was reported by 3 articles (9.4%), all of which utilized ad hoc cohort selection and were the only included studies that were industry funded. Foot and Ankle Injury Rate A total of 25 articles compared foot and ankle injury rates on artificial turf and natural grass. The greatest proportion of these studies (12/25; 48.0%) reported a higher rate of foot and ankle injuries on artificial turf than natural grass, whereas 10 (40.0%) found no difference in foot and ankle injury rates between playing surfaces, and 3 (12.0%) reported a higher foot and ankle injury rate on natural grass. Of these 3 studies, 2 (66.7%) utilized ad hoc cohort selection and were industry funded. Although a relatively high proportion of studies that reported on new-generation turf (9/19; 47.4%) found a higher risk of foot and ankle injury on artificial turf, that finding was even more frequently reported in ear- lier articles that examined old-generation turf (3/4; 75.0%). Knee Injury Rate A total of 32 articles compared knee injury rates on artifi- cial turf and natural grass. Over half of these studies (19/ 32; 59.4%) found no difference in knee injury rates between artificial turf and natural grass, whereas 8 studies (25.0%) reported a higher knee injury rate on artificial turf, and 5 studies (15.6%) reported a higher knee injury rate on nat- ural grass. Over two-thirds of articles (14/19; 73.7%) that examined knee injury rates on new-generation turf reported no difference in knee injury rates between the 2 playing surfaces, compared with a majority of studies (4/ 7; 57.1%) that reported a higher knee injury rate on old- generation turf compared with natural grass. A majority of articles (14/16; 87.5%) reported no difference in knee injury rates among soccer athletes, and 8 of 14 articles (57.1%) examining football athletes reported a higher knee injury rate on artificial turf. All 3 of the industry- funded studies reported no difference in knee injury rate between the two playing surfaces. Hip Injury Rate A total of 13 articles compared hip injury rates on artificial turf and natural grass. Of these studies, 11 (84.6%) reported no difference in hip injury rates between playing surfaces, while the remaining 2 studies (15.4%) reported a higher hip injury rate on natural grass. Of the 2 studies that found a higher risk of hip injuries on natural grass, both utilized ad hoc cohort selection, and 1 (50.0%) received industry fund- ing. None of the included articles reported hip injury rates in football athletes, and none examined old-generation turf. DISCUSSION Although the heterogeneity of the available literature pre- cludes a quantitative meta-analysis, this qualitative sys- tematic review of study outcomes suggests that the rates Figure 5.Diagram showing the conclusion of each article with regard to injury rates on artificial turf and natural grass, with articles classified by level of competition. Figure 6.Diagram showing the conclusion of each article with regard to injury rates on artificial turf and natural grass, with articles classified by artificial turf type. Gen, generation. 1618 Gould et al The American Journal of Sports Medicine of overall injuries, hip injuries, and knee injuries are similar between playing surfaces. Earlier studies suggested a greater risk of these types of injuries on old-generation turf, but more recent data note an equivalent injury risk on new-generation turf compared with natural grass for most athletes. Foot and ankle injury rates are a notable exception to this trend in that the risk of foot and ankle inju- ries has remained higher on new-generation turf compared with natural grass, though still less than that on old-gener- ation turf. These conclusions were not affected by the con- flicting findings of the 3 included studies that received financial support from the artificial turf industry. A majority of the included studies in this systematic review utilized ad hoc cohort selection, which raises con- cerns about the study design. Study cohorts that are defined in an ad hoc manner introduce the possibility of bias because of differences that may exist between individ- ual athletic programs with regard to injury-reporting ten- dencies. Although some teams may consistently and accurately report athletes’ injuries, others may tend to underreport injuries whether because of inadequate docu- mentation or underlying cultural elements that discourage athletes and medical personnel from disclosing injuries when they occur. These issues are of particular concern at the youth and high school levels in which many schools are unable to employ a full-time athletic trainer or arrange sideline physician coverage at sporting events.15,23 The potential effect of differences in injury-reporting practices can be diminished by studying predefined groups of ath- letes or athletic teams that are not created solely for the purpose of the study. For instance, including entire divi- sions or leagues may have less potential for bias than studying an ad hoc collection of teams that are selected by the study investigator. Studies sponsored by the National Football League provide an ideal model for avoid- ing this problem by utilizing comprehensive, standardized injury reporting and including all teams in the league.12,16 Among the 32 articles that compared overall injury rates, a slight majority reported no difference in the injury risk between playing surfaces. Although one-third of articles reported a higher overall injury rate on artificial turf, half of these studies1,2,5,13,24,27 utilized first- and sec- ond-generation turf types that are now considered obso- lete. Thus, whereas a higher overall injury rate might have existed on earlier generations of artificial turf, the more recent literature indicates that this risk has been ameliorated with the widespread adoption of new-genera- tion turf since it was developed in the late 1990s. There were 3 outlier articles that found a higher overall injury rate on natural grass compared with new-genera- tion turf.17-19 These studies all utilized ad hoc cohort selec- tion and thus had a high inherent risk of bias, a concern acknowledged by the author himself. All 3 studies were also supported by turf industry funding. Our results with regard to the overall injury rate coincide with the findings of previous narrative reviews,7,31 which also concluded that the risk of overall injuries appears to be similar between artificial turf and natural grass. Of the 25 included articles that examined foot and ankle injury rates in isolation, the greatest proportion found a higher foot and ankle injury rate on artificial turf, and this trend persisted when studies examining new- generation turf were analyzed separately. Only 3 articles17,19,26 reported a higher risk of foot and ankle inju- ries on natural grass, 2 of which utilized ad hoc cohort selection and received artificial turf industry funding.17,19 Thus, the literature appears to support the conclusion that the risk of foot and ankle injuries is at least equivalent between playing surfaces and may be higher on artificial turf. These findings are consistent with previous narrative reviews that have concluded a higher risk of foot and ankle injuries on artificial turf.28,31,32 The literature results are heterogeneous regarding the potential association between playing surface and knee injury. Although half of all articles reported no difference in knee injury rates between playing surfaces, some articles found a higher knee injury rate on artificial turf, and others found a higher knee injury rate on natural grass. Analysis of the studies that utilized new-generation artificial turf revealed a higher proportion of these articles that found no difference in knee injury rates. Interestingly, all 3 of the articles reporting a higher knee injury rate on new-generation artificial turf8,12,16 were conducted among football players at the collegiate or professional level, sug- gesting that there may be unique factors in the elite foot- ball population that predispose these athletes to a higher risk of knee injuries on artificial turf compared with natu- ral grass. These findings correspond with the results of a previous systematic review that reported a higher risk of anterior cruciate ligament ruptures on artificial turf for football players but not for soccer players.4 Taken together, the whole body of relevant literature suggests that the risk of knee injuries is similar on artificial turf and natural grass for most athletes but that football play- ers, particularly those at high levels of competition, may be more likely to sustain a knee injury on artificial turf than natural grass. Relatively few articles in the literature have compared hip injury rates on artificial turf and natural grass. Of these 13 studies, the majority found no difference in hip injury rates between playing surfaces, whereas only 2 articles cited a higher risk of hip injuries on natural grass. Consistent with observations in overall injuries and foot and ankle injuries, both of the articles that reported a higher hip injury rate on natural grass utilized ad hoc cohort selection, and 1 of the 2 studies3,19 was funded by the artificial turf industry.19 The only study not funded by the turf industry that found a higher hip injury rate on natural grass was a prospective cohort investigation that examined injury rates in a small ad hoc group of the Saudi National Team soccer players that yielded a very low number of injuries.3 The findings of this systematic review appear to indicate that the risk of hip injuries is comparable between artificial turf and natural grass. There were several limitations to this systematic review. The wide variability in study methods, particularly in terms of how athlete exposures were reported, made it impossible to perform a quantitative meta-analysis using aggregate risk ratios. Our systematic review design was unable to account for the fact that the underlying injury rates among different sports, levels of competition, and injury settings may be inherently different. Similarly, our methods did not permit the assessment of other varia- bles that may affect injury rates such as differences in turf AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1619 composition, athletic footwear, and field conditions. No restrictions were made in terms of study quality, and no formal weighting process was performed, thereby limiting our ability to differentiate the more reliable injury data from the less reliable data among the included articles. For these reasons, our systematic review should be inter- preted as a global snapshot of the literature, and our find- ings are not intended to replace the interpretation of high- quality individual studies that focus on specific athletic populations with specific types of injuries. CONCLUSION The available body of literature suggests a higher rate of foot and ankle injuries on artificial turf compared with nat- ural grass on both old- and new-generation turf. High- quality studies also suggest that the rates of knee injuries and hip injuries are similar between playing surfaces, although elite-level football athletes may be more predis- posed to knee injuries on artificial turf compared with nat- ural grass. Only a few articles in the literature reported a higher overall injury rate on natural grass compared with artificial turf, and all of these studies received finan- cial support from the artificial turf industry. ACKNOWLEDGMENT The authors thank Lyn Camire Jones, MA, ELS, of the Depart- ment of Orthopaedic Surgery, MedStar Union Memorial Hospi- tal, for editorial assistance and C. Scott Dorris, MLIS, AHIP, for assistance in performing the literature search. ORCID iDs Heath P. Gould https://orcid.org/0000-0002-8941-8811 Gregory P. Guyton https://orcid.org/0000-0002-1238-3673 An online CME course associated with this article is avail- able for 1 AMA PRA Category 1 CreditTM at https:// www.sportsmed.org/aossmimis/Members/Education/AJSM _Current_Concepts_Store.aspx. In accordance with the standards of the Accreditation Council for Continuing Med- ical Education (ACCME), it is the policy of The American Orthopaedic Society for Sports Medicine that authors, edi- tors, and planners disclose to the learners all financial rela- tionships during the past 12 months with any commercial interest (A ‘commercial interest’ is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients). Any and all disclosures are provided in the online journal CME area which is provided to all participants before they actually take the CME activity. In accordance with AOSSM policy, authors, editors, and planners’ participation in this educa- tional activity will be predicated upon timely submission and review of AOSSM disclosure. Noncompliance will result in an author/editor or planner to be stricken from participating in this CME activity. REFERENCES 1. Adkison JW, Requa RK, Garrick JG. Injury rates in high school foot- ball: a comparison of synthetic surfaces and grass fields.Clin Orthop Relat Res. 1974;99:131-136. 2. Arnason A, Gudmundsson A, Dahl HA, Johannsson E. Soccer injuries in Iceland. Scand J Med Sci Sports. 1996;6(1):40-45. 3. Almutawa M, Scott M, George KP, Drust B. The incidence and nature of injuries sustained on grass and 3rd generation artificial turf: a pilot study in elite Saudi national team footballers.Phys Ther Sport. 2014;15(1):47-52. 4. Balazs GC, Pavey GJ, Brelin AM, Pickett A, Keblish DJ, Rue JP. Risk of anterior cruciate ligament injury in athletes on synthetic playing sur- faces: a systematic review.Am J Sports Med. 2015;43(7):1798-1804. 5. Bramwell ST, Requa RK, Garrick JG. High school football injuries: a pilot comparison of playing surfaces.Med Sci Sports. 1972;4(3):166-169. 6. Dowling AV, Corazza S, Chaudhari AM, Andriacchi TP. Shoe-surface friction influences movement strategies during a sidestep cutting task: implications for anterior cruciate ligament injury risk.Am J Sports Med. 2010;38(3):478-485. 7. Dragoo JL, Braun HJ. The effect of playing surface on injury rate: a review of the current literature.Sports Med. 2010;40(11): 981-990. 8. Dragoo JL, Braun HJ, Harris AH. The effect of playing surface on the incidence of ACL injuries in National Collegiate Athletic Association American Football.Knee. 2013;20(3):191-195. 9. Drakos MC, Hillstrom H, Voos JE, et al. The effect of the shoe-sur- face interface in the development of anterior cruciate ligament strain. J Biomech Eng. 2010;132(1):011003. 10. Drakos MC, Taylor SA, Fabricant PD, Haleem AM. Synthetic playing surfaces and athlete health.J Am Acad Orthop Surg. 2013;21(5):293- 302. 11. Ford KR, Manson NA, Evans BJ, et al. Comparison of in-shoe foot loading patterns on natural grass and synthetic turf.J Sci Med Sport. 2006;9(6):433-440. 12. Hershman EB, Anderson R, Bergfeld JA, et al. An analysis of specific lower extremity injury rates on grass and FieldTurf playing surfaces in National Football League games: 2000-2009 seasons.Am J Sports Med. 2012;40(10):2200-2205. 13. Jamison S, Lee C. The incidence of female hockey injuries on grass and synthetic playing surfaces.Aust J Sci Med Sport.1989;21:15-17. 14. Jastifer JR, McNitt AS, Mack CD, et al. Synthetic turf: history, design, maintenance, and athlete safety.Sports Health. 2019;11(1):84-90. 15. Jones NS, Sethi N, Wieschhaus K, et al. Medical supervision of Illi- nois public and private high school athletics.Phys Sportsmed. Pub- lished online December 31, 2020. doi: 10.1080/00913847.2020 .1868954 16. Mack CD, Hershman EB, Anderson RB, et al. Higher rates of lower extremity injury on synthetic turf compared with natural turf among National Football League athletes: epidemiologic confirmation of a biomechanical hypothesis.Am J Sports Med. 2019;47(1):189-196. 17. Meyers MC. Incidence, mechanisms, and severity of game-related college football injuries on FieldTurf versus natural grass: a 3-year prospective study.Am J Sports Med. 2010;38(4):687-697. 18. Meyers MC. Incidence, mechanisms, and severity of match-related collegiate women’s soccer injuries on FieldTurf and natural grass sur- faces: a 5-year prospective study.Am J Sports Med. 2013;41(10): 2409-2420. 19. Meyers MC. Incidence, mechanisms, and severity of match-related collegiate men’s soccer injuries on FieldTurf and natural grass surfaces: a 6-year prospective study.Am J Sports Med. 2017;45(3):708-718. 20. Moher D, Liberati A, Tetzlaff J, Altman DG; the PRISMA Group. Pre- ferred Reporting Items for Systematic Reviews and Meta-Analyses: the PRISMA statement.J Clin Epidemiol. 2009;62(10):1006-1012. 21. O’Leary F, Acampora N, Hand F, O’Donovan J. Association of artifi- cial turf and concussion in competitive contact sports: a systematic review and meta-analysis.BMJ Open Sport Exerc Med. 2020;6(1): e000695. 1620 Gould et al The American Journal of Sports Medicine 22. Ouzzani M, Hammady H, Fedorowicz Z, Elmagarmid A. Rayyan: a web and mobile app for systematic reviews.Syst Rev. 2016;5(1):210. 23. Post EG, Roos KG, Rivas S, Kasamatsu TM, Bennett J. Access to athletic trainer services in California secondary schools.J Athl Train. 2019;54(12):1229-1236. 24. Powell JW. Incidence of injury associated with playing surfaces in the National Football League 1980-1985.Athl Train. 1987;22(3): 202-206. 25. Rennie DJ, Vanrenterghem J, Littlewood M, Drust B. Can the natural turf pitch be viewed as a risk factor for injury within association foot- ball?J Sci Med Sport. 2016;19(7):547-552. 26. Soligard T, Bahr R, Andersen TE. Injury risk on artificial turf and grass in youth tournament football.Scand J Med Sci Sports. 2012;22(3): 356-361. 27. Stevenson MJ, Anderson BD. The effects of playing surfaces on inju- ries in college intramural touch football. NIRSA 1981;Recreat Sport J(5):59-64. 28. Taylor SA, Fabricant PD, Khair MM, Haleem AM, Drakos MC. A review of synthetic playing surfaces, the shoe-surface interface, and lower extremity injuries in athletes.Phys Sportsmed. 2012;40(4):66-72. 29. Villwock MR, Meyer EG, Powell JW, Fouty AJ, Haut RC. Football playing surface and shoe design affect rotational traction.Am J Sports Med. 2009;37(3):518-525. 30. Williams JH, Akogyrem E, Williams JR. A meta-analysis of soccer injuries on artificial turf and natural grass.J Sports Med (Hindawi Publ Corp). 2013;2013:380523. 31. 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For reprints and permission queries, please visit SAGE’s Web site at http://www.sagepub.com/journals-permissions AJSM Vol. 51, No. 6, 2023 Turf Versus Grass Injury Rates 1621 1 From:Louise Mygatt <louisemygatt@gmail.com> Sent:Monday, March 17, 2025 12:30 PM To:Town Of Ithaca Planning Cc:pbstaff@cityofithaca.org Subject:artificial turf Attachments:met-pfas-statement-fieldturf-1 (copy).pdf; PFAS detected in all components of Artificial Turf - Academic Municipal & Other Tests Aug 2024_tcm18-386957-1.pdf **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town Planning Board Members, The attached August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification. This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thres holds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. 2 Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee. Additionally, I want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment.Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Dr. Louise Mygatt To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. ReplyReply allForward Add reaction PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 1 Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts August 2024 A number of organizations have conducted PFAS testing in artificial turf materials. These include academic studies as well as testing conducted by nonprofit organizations, municipalities, and manufacturers or vendors, sometimes with the assistance of consulting firms. This document provides a compilation of results that have been reported from many of these testing efforts. This document is a companion to an earlier Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods.1 Please see that publication for background about sources of PFAS in artificial turf, and for a discussion of key considerations related to test methods. For another recent summary of test results, see the New Jersey Department of Environmental Protection’s Technical Memorandum on PFAS in Artificial Turf.2 Additional detail on PFAS test methods can be found in ITRC’s report, Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance.3 Test results are summarized below for academic studies; regional and municipal studies; nonprofits, community organizations, and journalists; and manufacturers. Testing has been carried out using a variety of methods and approaches. This document does not provide an evaluation of the robustness, accuracy, or precision of the methods or results. Academic studies Academic studies have explored a range of methods for assessing PFAS in artificial turf materials, and expanded the information available on the presence of PFAS in these materials. Results from these studies are summarized in Table 1. Lauria et al. 2022. Researchers measured total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS in carpet backing, carpet blades, and infill samples from 17 artificial turf fields in Stockholm, Sweden.4 Infills were composed of thermoplastic olefins, thermoplastic elastomer (TPE), styrene-butadiene rubber (SBR), sand, ethylene propylene diene monomer rubber (EPDM), and organic materials (i.e., cork, bark, and coconut). TF was measured in all samples. TF was higher in thermoplastics and EPDM than in SBR and organic material infills. EOF was measured in 42% of samples. Among specific PFAS examined in the targeted analysis, long chain perfluoroalkyl carboxylic acids (PFCAs) were detected most frequently. The authors explain that “collectively, these results point toward polymeric organofluorine (e.g., fluoroelastomer, polytetrafluoroethylene, and polyvinylidene fluoride), consistent with patent literature.”4 PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 2 Authors also estimated that each field contained 0.315–17.439 kg of fluorine that would eventually be landfilled or incinerated. Zuccaro et al. 2022. Zuccaro et al. (2022) conducted a pilot study assessing an extraction-analysis method to identify and quantify fluorotelomer alcohols (FTOHs) in artificial turf carpet and crumb rubber infill made with shredded used tires.5 FTOHs make up a “class of PFAS known to be volatile precursors of other, more harmful PFAS such as PFOA.” Samples were extracted using a solvent and analyzed by gas chromatography- mass spectroscopy (GC-MS). 8:2 FTOH was measured in artificial turf fibers (1.0 ng/ µL (ppm)) and in crumb rubber infill. Whitehead, 2023. Whitehead (2023) used several testing methods to analyze 27 samples of artificial turf blades to determine the presence of PFAS.6 For context, Whitehead explains that fluorinated polymer processing aids (fPPAs) are “added directly to raw plastic resins” prior to the resins being “heated, mixed, and extruded or blown into a final plastic product.” Thus, the fluorinated polymer is incorporated into the final plastic product as part of the manufacturing process. Whitehead used PIGE to measure TF in samples before and after an extraction. TF ranged from below detection limit to 2.94 µg F/cm2. Results showed only minor changes after extraction, suggesting that “much of the fluorine present in these samples is from nonextractable, potentially polymeric, sources of fluorine." This is consistent with the uses of fPPAs in plastic and rubber products described in the existing literature. Whitehead also conducted targeted tested for 21 individual PFAS using liquid chromatography tandem mass spectrometry (LC-MS/MS). All artificial turf samples had detectable amounts of at least one type of PFAS, though four of the samples had concentrations below the quantification limit. PFAS with a chain of eight or fewer carbons (short-chain) such as PFBA, PFOA, and PFHxS, were measured most frequently. The median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). Fourier-transform infrared (FTIR) spectroscopy was used to characterize carbon-fluorine bonds in artificial turf samples. Results were compared with fluorinated polymer processing aids that are added to artificial turf polymers. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." This information further supports the possibility that fluorinated polymers were added to the resin. A TOP assay was performed on four samples including artificial turf and product packaging. Because this testing included both artificial turf and other plastic products, this information is relevant primarily for refining methodologies. The three samples that had lower total concentrations of PFAS before oxidation did not have significant changes in concentration after oxidation. This was likely because those samples did not contain substantial quantities of the precursor PFAS that break down into the degradation products that were measured in the TOP assay. One sample had a higher concentration of PFAS before oxidation, and showed a higher concentration of degradation products after oxidation. This suggested that the sample contained higher quantities of the precursors that were measured in the TOP assay. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 3 A conclusion of this study was that “these results suggest that much of the total fluorine signals measured in these plastics are from nonextractable, likely polymeric sources. These results are aligned with what might be expected, given fluorinated polymer processing aids being polymeric PFAS. This highlights that targeted analysis techniques are likely to miss significant portions of the PFAS that are present on various plastic products.” In other words, this study further supports the importance of carefully choosing test methods that can accurately characterize PFAS content in artificial turf materials. Table 1. Summary of PFAS testing from academic studies. Source Summary Lauria et al. (2022)4 Total fluorine (TF), extractable organic fluorine (EOF), and targeted PFAS tests in 51 samples of artificial turf from fields in Stockholm, Sweden. Samples were separated into carpet backing, carpet blades, and infill. TOTAL FLUORINE • “TF was observed in all 51 samples (ranges of 16–313, 12–310, and 24–661 μg of F/g in backing, filling, and blades, respectively).” • TF was higher in thermoplastics and EPDM than in styrene butadiene rubber (SBR) and organic material infills. EXTRACTABLE ORGANIC FLUORINE • Backing: range from <LOD - 145 ng of F/g (ppb) • Infill: range from <LOD - 179 ng of F/g (ppb) • Blades: range from <LOD - 192 ng of F/g (ppb) TARGETED ANALYSIS • Results were reported as the sum of fluorine in a sample. • Backing: <LOD - 0.63 ng of F/g (ppb) • Infill: <LOD - 0.15 ng of F/g (ppb) • Blades: “absent” Zuccaro et al. (2023)5 A pilot study assessing an extraction-analysis method to measure fluorotelomer alcohols (FTOH) in artificial turf carpet and crumb rubber infill. Samples were extracted using a solvent and analyzed by gas chromatography-mass spectrometry (GC-MS) in scanning ion mode (SIM). FLUOROTELOMER ALCOHOLS PILOT TEST: • “8:2 FTOH was detected in artificial turf fiber and crumb rubber infill samples at concentrations of 1.0 and 0.71 ng/μL [ppm], respectively. This translates to 300ng 8:2 FTOH/g artificial turf fiber and 110ng 8:2 FTOH/g crumb rubber. By contrast, 4:2 FTOH and 6:2 FTOH were not found to be present in detectable levels.” Whitehead (2023) (dissertation)6 Analyzed PFAS in 27 samples of artificial turf blades using several methods. TOTAL FLUORINE • Measured using particle-induced gamma ray emission (PIGE) spectroscopy. • TF ranged from <LOD to 2.94 µg F/cm2. TARGETED ANALYSIS Targeted testing for 21 PFAS using liquid chromatography tandem mass spectrometry (LC- MS/MS) PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 4 • PFAS were detected in all samples. Median sum of PFAS concentrations in the turf samples was 5.1 ng/g (ppb) and the highest sum of PFAS concentrations was 41.7 ng/g (ppb). ORGANIC FLUORINE • Organic fluorine was measured using fourier-transform infrared (FTIR) spectroscopy. Results were “indicative of the presence of organic fluorine in these samples, with a strong degree of similarity between spectra collected from samples to that of raw fluorinated polymer processing aids." TOP ASSAY (four samples only) • “[T]he samples which had low or small sum of PFAS concentrations before TOP assay didn’t have significant changes in their sum of PFAS concentrations. The sample which had the highest sum of PFAS concentrations before TOP assay showed a more significant increase in measured concentrations.” • Results suggest that “the concentrations of fluorine measured through PIGE are likely indicative of PFAS which does not undergo transformation” into the compounds measured in the TOP assay. Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Regional and Municipal Studies The Martha’s Vineyard Commission in Massachusetts tested artificial turf carpet, wood infill, shock pad, and two adhesives used during the installation of an artificial turf field.7 The analyses included targeted analyses; TOP assay; and total fluorine analysis. Some of the results were derived using the synthetic precipitation leaching procedure (SPLP), an EPA method "designed to determine the mobility of both organic and inorganic analytes present in liquids, soils, and wastes."8 PFAS were detected in all materials. For example, the total organic fluorine analysis measured 70 ppm in the carpet, and lower quantities in other materials. Additional results are summarized in Table 2. The City of Portsmouth, New Hampshire installed an artificial turf field in 2021. The product was marketed as “PFAS-free.” Concerned residents and an environmental advocacy group led testing on samples of new artificial turf material. An independent laboratory measured TF on artificial turf blades, backing, and shock pad. TF was between 16 ppt – 119 ppt in the materials, indicating likely presence of PFAS.9 Dr. Graham Peaslee, a PFAS expert at University of Notre Dame, reviewed these results and explained “these total fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial grass.”9 The City of Portsmouth later initiated further testing with help from a consulting group. This effort included a targeted analysis that tested for 70 individual PFAS chemicals; TOP assay; and a non-targeted analysis. The materials tested included artificial turf carpet, walnut shell infill, and shock pad. The results showed presence of several types of PFAS in the carpet, infill, and shock pad. For example, in the walnut shell infill, the targeted analysis detected six PFAS, and the TOP assay detected four PFAS post-oxidation.10 Results are summarized in Table 2. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 5 Table 2. Summary of PFAS testing led by regional institutions and municipalities. Source Summary Martha’s Vineyard, MA (2020).7 Laboratory results interpreted by consultants at Tetra Tech Analysis of PFAS in samples of artificial turf carpet, wood infill, shock pad, and two adhesives used during field construction. TARGETED ANALYSIS “Total PFAS by isotope dilution method” • Detected certain PFAS at concentrations above the method detection limit (MDL) but below the RL, yielding the following estimated values: Carpet: PFPeA: 0.148 ng/g (ppb); Wood infill: PFPeA: 0.455 ng/g (ppb); Adhesive: 6:2FTS: 0.848 ng/g (ppb). Synthetic Precipitation Leaching Procedure • “Select PFAS compounds were detected in the SPLP analysis that were not detected in the total PFAS analysis.” • “The PFAS6 compounds were detected in the SPLP analysis of the [turf carpet] (1.02 ng/L), [shock pad] (1.40 nanograms per liter(ng/L)), the [wood infill] (5.01 ng/L) and the [adhesive] (0.395 ng/L). However, these PFAS6 compounds were not detected in the total PFAS analysis at concentrations above the RL or the MDL.” (All units shown here are equivalent to ppt.) • “The detection of PFAS compounds in the samples of the synthetic turf components via SPLP PFAS analysis but not via total PFAS analysis may suggest that these products contain PFAS compounds that were not extractable via the analytical method utilized for total PFAS analysis (isotope dilution method), but were extractable by the more rigorous SPLP extraction process.” TOTAL OXIDIZABLE PRECURSOR (TOP) ASSAY • PFAS were not detected during the pre-oxidation measurements. • The measurements made after oxidation detected perfluorobutanoic acid (PFBA) in all sample materials at concentrations above the method detection limit but below the reporting limit, yielding estimated values between 2.11 ng/g to 28.7ng/g. • “Perfluoroheptanoic acid (PFHpA) was detected in the oxidized sample of the [wood infill] at a concentration of 20.4 ng/gPFAS6: 5.01 ng/L (ppt)” • “Perfluoropentanoic acid (PFPeA) was detected in the oxidized sample of the [adhesive] at a concentration of 6.08 ng/g.” This concentration was above the method detection limit but below the reporting limit, yielding an estimated value. TOTAL ORGANIC FLUORINE • “Total organic fluorine was detected in the [carpet] at a calculated concentration of 70 parts per million (ppm), the [shock pad] (26 ppm), [an adhesive] (10 ppm), and [a second adhesive] (11 ppm). Fluoride ions were not detectable above the RL of 10 ppm, suggesting that the total fluorine detected in these samples likely represents primarily organic fluorine. However, because the RL in some cases is close to the detected concentration of total fluorine, it is possible that the portion organic fluorine could be lower. Total fluorine was not detected in the sample of the [wood infill] above the RL of 10 ppm.” Additional note from consultant report The consultant noted that there were difficulties in the laboratory’s approach. “The detection limits achieved by the laboratory were elevated because of the limited sample weight utilized during extraction and the dilutions required by the low density sample matrix.” PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 6 Portsmouth, NH (2021) initial community testing9 The environmental group Non Toxic Portsmouth, with guidance from the Ecology Center, initiated PFAS testing of new samples of artificial turf blades, carpet backing, and shock pad. An independent laboratory measured total fluorine in these materials. TOTAL FLUORINE • Carpet: TF: 83- 119 ppm • Backing: TF: 16 ppm • Shock pad: TF: 61 ppm • Comments on results by Dr. Graham Peaslee at University of Notre Dame: “These total fluorine measurements are typical for plastics that have been manufactured with PFAS- based polymer processing aids – which will leave residues of these PFAS at the part-per- million level on the artificial grass.” 9 Portsmouth, NH (2022) testing initiated by City of Portsmouth. Laboratory results interpreted by consultants at TRC10 Eurofins Lancaster Labs tested PFAS artificial turf carpet, walnut shell infill, and a foam shock pad. Results summarized here show presence of substances only. See full report for concentrations. TARGETED TESTING AND TOP ASSAY PFAS was measured pre- and post- oxidation. The pre-oxidation analysis measured “70 individual [targeted] PFAS using a modified version of USEPA Method 537.1, with isotope dilution liquid chromatography/dual mass spectrometry” in samples of material. This method is considered a targeted test method. Samples were also oxidized and measured for PFAS precursors. • Carpet: There were no detectable concentrations of PFAS in pre-oxidized samples. • Eight individual PFAS were detected in samples after oxidation (one PFAS, 6:2 FTSA, was also detected in a blank sample). For example, “PPF acid was detected at 1.08 ng/g [ppb].” • Shock pad: Three PFAS were detected in pre-oxidized samples (one PFAS, 6:2 FTSA, was also detected in a blank sample). Six PFAS were detected in samples after oxidation. • Walnut shell infill: Six PFAS were detected in pre-oxidized samples. For example, “PFMOAA was detected at a concentration of 5.16 ng/g [ppb] and PPF acid was detected at a concentration of 41 ng/g [ppb].” Four PFAS were detected in samples after oxidation. NON-TARGETED ANALYSIS “Non-targeted QTOF-MS [quadrupole time of flight mass spectrometry] analyses were performed on each sample to determine if “other” PFAS were present that were not included in the analysis of the 70 individual PFAS.” • Results were “qualitative estimations of presumptive positives.” Several additional chemicals were found in these samples, but only one, bis(2,2,3,3,4,4,4- heptafluorobutyl) carbonate, was tentatively identified in the carpet sample. The other chemicals were reported as “unknown.” Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. “PFAS6” refers to the six PFAS regulated in drinking water in Massachusetts at the time the testing was conducted: PFOS, PFOA, PFHxS, PFNA, PFHpA and PFDA. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 7 Nonprofits, Community Organizations, and Journalists A number of nonprofits, community organizations, and journalists have conducted PFAS testing on artificial turf. Below are some examples. Original testing reported in The Intercept. In 2019, two nonprofit organizations tested artificial turf carpet and found evidence of the presence of PFAS in the material. Their results were reported in The Intercept.11 The organizations tested backing of both new turf and older, discarded turf. They also tested a number of samples of artificial grass blades (carpet fibers). They detected 6:2-fluorotelomer sulfonic acid (6:2 FTSA) in the backing of the new turf sample. 6:2 FTSA has a 6-carbon chain, and is considered a short-chain PFAS because of the way in which it breaks down. In many cases, short-chain PFAS have been adopted as substitutes for longer-chain PFAS. They detected perfluorooctane sulfonate (PFOS) in the backing of the discarded, older turf sample. PFOS is a long-chain PFAS that is no longer manufactured in the US due to concerns about health and environmental effects. They also tested a number of synthetic turf fiber samples and found that all of them contained quantities of fluorine that suggest the presence of PFAS.11 Since the initial finding of PFAS in artificial turf, other community groups and municipalities have submitted samples of new and older turf to commercial and research laboratories for various types of PFAS analyses. Woodbridge, CT. Residents in the town of Woodbridge, CT initiated testing of stormwater samples collected from a swale located beside an artificial turf installation site.12 The artificial turf was marketed as a PFAS- free product. The lab used a targeted PFAS method to test 18 PFAS in stormwater runoff before and after the installation of an artificial turf field at Amity Regional High School in 2021. The levels of PFOA and PFOS measured after installation were higher than the levels measured before installation. Three other PFAS were also detected in the post-installation stormwater samples (see Table 3). Philadelphia Inquirer. The Philadelphia Inquirer obtained samples of the artificial turf samples used by the Philadelphia Phillies from 1977 – 1981. They shared samples with researchers at the University of Notre Dame and an independent lab for PFAS testing. They found the presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). PEER and CEH. In 2024, both PEER13 and CEH14,15 have conducted additional testing, as shown in Table 3. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 8 Table 3. Summary of PFAS testing initiated by nonprofits, community organizations, and journalists. Source Summary NONPROFIT AND COMMUNITY ORGANIZATIONS Testing reported in The Intercept (2019).11 Results summarized by New Jersey Department of Environmental Protection.2 Targeted and total fluorine testing conducted on new turf carpet samples; targeted testing conducted on used sample. TARGETED ANALYSIS • New turf carpet sample: 6:2 FTSA: 300 ppt • Used turf carpet sample: PFOS: 190 ppt TOTAL FLUORINE ANALYSIS • New turf carpet blades: 44-255 ppm Woodbridge, CT (2021)12 Samples of stormwater runoff were collected before and after the installation of an artificial turf field from a swale located near the artificial turf field installation site. Targeted analysis EPA method 537.1 was used to test the runoff for 18 PFAS. TARGETED ANALYSIS of runoff • Before installation: PFOA: 4.60 ng/L (ppt); PFOS: 5.52 ng/L (ppt) • After installation: PFOA: 7.57 ng/L (ppt); PFOS: 6.44 ng/L (ppt); PFBS: 1.39 ng/L (ppt); PFHxA: 3.33 ng/L (ppt); PFHpA: 2.04 ng/L (ppt) Preliminary dermal exposure tests by Public Employees for Environmental Responsibility (PEER)13 Used skin wipes to measure PFAS on four individuals before and after play. Results showed differences in pre- and post-play PFAS levels for artificial turf and grass. Center for Environmental Health (CEH)14,15 CEH tested samples of artificial grass used for residential applications. PFOS was detected during testing. Based on the levels detected, CEH sent California Proposition 65 notices of violation to relevant parties. JOURNALIST Philadelphia Inquirer (2023)16 The Philadelphia Inquirer purchased samples of artificial turf carpet used by Philadelphia Phillies from 1977 – 1981 and sent samples to Eurofins Lancaster Labs and University of Notre Dame. Eurofins conducted targeted testing for 70 individual PFAS. TARGETED ANALYSIS • Testing indicated presence of 16 PFAS, including PFOA (12 ppt) and PFOS (5.5 ppt). Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. Manufacturers Determining which chemicals are present in a product can be challenging because chemical contents are frequently not disclosed by the manufacturer. In response to public concern about PFAS, some artificial turf PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 9 manufacturers have recently begun providing test data of their own. Table 5, below, shows examples of two manufacturers that have provided test data. As shown in the table, one manufacturer used targeted analysis to test for the presence of PFOA and PFOS.17 Because the manufacturer only examined two chemicals, these test data are of limited value in determining whether PFAS are present in the product. In addition, the detection limit was 100 ppt, so the two chemicals could not be accurately measured or detected below 100 ppt.17 Neither chemical was detected above this threshold. Testing from another manufacturer was discussed in an article in the Philadelphia Inquirer. The manufacturers stated that the artificial turf was free of PFAS based on lab testing. However, experts consulted by the journalists suggested that the laboratory test results had limited value, in part because of high detection limits.18 In some cases, targeted tests have been used to inform PFAS-free statements. For example, one manufacturer states that their “entire range for artificial products showed non-detectable levels of PFAS at 100 parts per trillion.”19 This statement was based on results from measuring PFOS and PFOA only.17 In response to debates over PFAS-free claims, certain manufacturers have proposed definitions of the term “PFAS-free.” For example, one manufacturer defines a product as PFAS-free if it contains “less than 100 ppm total organic fluorine.”20 (The manufacturer cites a California regulatory threshold for PFAS in juvenile products.21) Table 4. Examples of PFAS testing led by manufacturers. Source Summary Artificial turf manufacturer example #1 (2023)17 The manufacturer sent sample a of artificial turf carpet to a lab for targeted analysis of PFOA and PFOS. The samples were “extracted via EPA method 3545A with the resulting solution analyzed via HPLC/TS/MS to determine the presence of each analyte. The lowest calibrated detection is at 100 parts per trillion.” TARGETED ANALYSIS OF PFOA AND PFOS • PFOA and PFOS: None detected below 100 ppt. Note: The test was set up to detect concentrations below 100 ppt. Artificial turf manufacturer example #2 (2022)22 Results summarized by The Philadelphia Inquirer (2024)18 The manufacturer sent samples of artificial turf marketed as PFAS-free to RTI Laboratories Inc. for targeted PFAS testing. TARGETED ANALYSIS • The laboratory’s summary of results stated that “all extractable PFAS compounds were non-detect at a level of 2-4 ug/kg (ppb).”22 • Experts consulted by The Philadelphia Inquirer expressed concerns about the testing methods and the high detection limits used. They noted that lower detection limits and a total organic fluorine test would have yielded results that are more informative.18 Notes: Summaries in this document do not include any evaluation of the robustness, accuracy, or precision of the methods or results. Concentrations are shown in the units that were used in the original source. We have also added ppm, ppb, or ppt in parentheses for ease of interpretation. <LOD = below level of detection. PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 10 Acknowledgments This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable Production). Comments on a draft of this document were provided by Susan Chapnick, MS; Wendy Heiger- Bernays, PhD; Kristen Mello, MSc; Gillian Miller, PhD; Nancy Rothman, PhD; Zhenyu Tian, PhD; and Heather Whitehead, PhD. This document is a companion to another Lowell Center publication, Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods. It also builds upon and updates an earlier fact sheet by the same authors and published by the Massachusetts Toxics Use Reduction Institute, “Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf Carpet” (2020). This report also draws upon information in Sandra Goodrow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection, State of New Jersey. Research for this report was supported by The Heinz Endowments. The Lowell Center for Sustainable Production uses rigorous science, collaborative research, and innovative strategies for communities and workplaces to adopt safer and sustainable practices and products to protect human health and the environment. The Lowell Center is composed of faculty, staff, and graduate students at the University of Massachusetts Lowell who work with citizen groups, workers, businesses, institutions, and government agencies to build healthy work environments, thriving communities, and viable businesses that support a more sustainable world. References 1. Lowell Center for Sustainable Production; University of Massachusetts Lowell. Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods, https://www.uml.edu/docs/PFAS-in-turf-Test-methods-July 2024_tcm18- 385224.pdf (July 2024). 2. Goodrow S, State of New Jersey Department of Envrionmental Protection. Technical Memorandum. Subject: PFAS in artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf (2023). 3. Interstate Technology Regulatory Council (ITRC). Per- and Polyfluoroalkyl Substances (PFAS): Technical/Regulatory Guidance, https://pfas-1.itrcweb.org/wp-content/uploads/2023/12/Full-PFAS-Guidance-12.11.2023.pdf (2023). 4. Lauria M, Naim A, Plassmann M, et al. Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from Stockholm, Sweden. Environ Sci Technol Lett 2022; 9: 666–672. 5. Zuccaro P, Licato J, Davidson E, et al. Assessing extraction-analysis methodology to detect fluorotelomer alcohols (FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber infill. Case Stud Chem Environ Eng; 100280. Epub ahead of print 2023. DOI: 10.1016/j.cscee.2022.100280. 6. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant to human health and the environment (dissertation), https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Selective_and_Sensitive_A nalysis_of_Compounds_Relevant_to_Human_Health_and_the_Environment/24869502 (2023). 7. Tetra Tech. Synthetic turf laboratory testing and analysis summary report, https://www.oakbluffsma.gov/DocumentCenter/View/7435/TetraTech-MVC-2021-02-26-TurfAnalysisReport_FINAL (February 2021). 8. U.S. Environmental Protection Agency. SW-846 Test Method 1312: Synthetic Precipitation Leaching Procedure, https://www.epa.gov/hw-sw846/sw-846-test-method-1312-synthetic-precipitation-leaching-procedure (2024). 9. Non Toxic Dover NH. Tests detect dangerous PFAS chemicals in Portsmouth’s new synthetic turf field. 2021, https://nontoxicdovernh.wordpress.com/2021/09/15/tests-detect-dangerous-pfas-chemicals-in-portsmouths-new- synthetic-turf-field/ (2021). PFAS in Artificial Turf: Results from academic, municipal, and other testing efforts 11 10. TRC. Technical Memorandum. Subject: Evaluation of PFAS in Synthetic Turf, https://www.cityofportsmouth.com/sites/default/files/2022-06/Technical Memorandum_Portsmouth_Final.pdf (2022). 11. Lerner S. Toxic PFAS Chemicals Found in Artificial Turf. The Intercept, 8 October 2019, https://theintercept.com/2019/10/08/pfas-chemicals-artificial-turf-soccer/ (8 October 2019, accessed 31 October 2019). 12. Prasad C. Artificial turf field- elevated levels of PFAS found. Letter to Oak Bluffs Planning Board, October 2, 2021., https://www.oakbluffsma.gov/DocumentCenter/View/6834/Chandra-Prasad-email-Oct-2-2021 (2021). 13. Public Employees for Environmental Responsibility (PEER). Press Release: PFAS in Artificial Turf Coats Players’ Skin, https://peer.org/pfas-in-artificial-turf-coats-players-skin/ (2024). 14. Center for Environmental Health. Notice of Violation: California Safe Drinking Water and Toxic Enforcement Act: Perfluorooctane Sulfonate (PFOS) in Artificial Grass, May 10, 2024. 60-Day Notice Document., https://oag.ca.gov/prop65/60-Day-Notice-2024-01833 (2024). 15. Nevins M. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf. CEH Press Release, March 4, 2024., https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/ (2024). 16. Laker B, Gambacorta D. How we were able to test artificial turf from Veterans Stadium and what the tests showed. Philadelphia Inquirer, 2023, https://www.inquirer.com/news/veterans-stadium-artificial-turf-samples-testing-pfas- forever-chemicals-cancer-20230307.html (2023). 17. Professional Testing Laboratory LLC. Test report (test number: 0301819), https://smartturf.com/wp- content/uploads/2023/11/r_301819_r_Materials-Analysis.pdf (2023, accessed 5 June 2024). 18. Gambacorta D, Laker B. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say. The Philadelphia Inquirer, 23 February 2024, https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial- turf-field-murphy-recreation-20240223.html (23 February 2024). 19. Nguyen A. A Deep Dive: The Importance of Non-Detectable PFAS, https://smartturf.com/a-deep-dive-pfas-and- artificial-grass/ (2023, accessed 5 June 2024). 20. AstroTurf. PFAS-free Synthetic Turf, https://astroturf.com/pfas-free-synthetic-turf/. 21. State of California. CA Health & Safety Code § 108945, https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=104.&title=&part=3.&cha pter=12.5.&article= (2022). 22. RTI Laboratories Inc. Spinturf PFAS Testing Results Nov 18, 2022, https://s3.documentcloud.org/documents/25002642/sprinturf-rti-labs-pfas-testing-11182022.pdf (2022). From: To: Subject: Sent: Tulesi Suresh Town Of Ithaca Planning Opposition to Artiﬁcial Turf 3/18/2025 8:05:03 AM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Good morning, Id like to submit a written comment opposing the installment of artificial turf on Cornell’s campus and off campus due to their negative impacts on environmental and human health. This decision goes against sustainability efforts and is not a wise decision. Best, Tulesi Suresh 1 March 11, 2025 Dear Members of the Town of Ithaca Planning Board, I am writing to you with an update to my previous letter from February 28, 2025 to present you with the most recent data and analysis to ensure that the public record is current. In response to concerns raised about artificial turf, a dedicated group of field hockey parents and alumnae undertook an exhaustive review of the 151-page bibliography provided by Zero Waste Ithaca on their website (dated February 10, 2025). Our approach was meticulous and data-driven: • We started with 1,539 hyperlinks embedded in the document, of which 877 were duplicates, leaving us with 662 unique sources. • We then excluded non-scientific materials, such as personal opinions, news articles, community letters, conference manuscripts, lawsuits, manufacturers information, statements from advocacy groups, and YouTube videos. These sources, while valuable in the context of public discourse, do not meet the rigorous standards of scientific research. • We also excluded 11 sources or hyperlinks that pointed to the same peer-reviewed study • We further refined our list by focusing only on peer-reviewed studies published in scientific journals, as these represent the highest standard of credible research. This process left us with 162 peer-reviewed studies, plus one EPA study that we included. Exhibit 1: Analysis of sources referenced in the bibliography of Zero Waste Ithaca (as of February 10, 2025) • Upon closer examination of the 163 peer-reviewed studies: o 106 of these studies did not address artificial turf at all. o 30 studies focused on turf containing infill materials, which is not relevant to this project because the proposed field will not use crumb rubber infill. o An additional 27 studies were not relevant because their subject was turf that was not only not the specific type of turf that is proposed, but not even in the general category of field hockey turf. These included studies whose subject was football 1,539 662 163 (877) (488) (11) Total Hyperlinks Duplicate Hyperlinks Unique Hyperlinks Non-peer-reviewed Sources Duplicate studies Peer-reviewed Studies 2 turf, general use recreational turf, park coverings, playground turf, as well as laminate flooring. Exhibit 2: Review of 163 peer-reviewed studies referenced in the bibliography of Zero Waste Ithaca (as of February 10, 2025) The updated number of peer-reviewed studies compared to my previous letter and analysis still leaves us with zero studies that demonstrate a relationship between the artificial turf in the proposal for the field hockey turf, and any harm caused to the environment or people. Again, thank you very much for your willingness to serve on the Planning Board and for all your hard work on this decision. I truly appreciate your service. Respectfully, Beatrice Lechner MD Associate Professor of Pediatrics (retired) Alpert Medical School of Brown University 163 (106) (30) (27) Peer-reviewed Studies Not Artifical Turf Turf with Infill Not FH Turf Relevant Scientific Studies 0 From: To: Subject: Sent: bethany ojalehto mays Town Of Ithaca Planning Planning Board submission: Correction to article on ﬁeld hockey turf by Z. Faraj 3/16/2025 1:24:00 PM Dear Planning Board staff; Appended below, I submit a letter of correction sent to The Cornell Daily Sun for inclusion in the public record for the Game Farm Road Project. This letter clarifies how Cornell's bad-faith SEQR segmentation has created a situation that exerts unusual emotional, intense public pressure upon the Planning Board to rush a project through without adequate environmental scrutiny of its cumulative impacts. This should also underscore the importance of a GEIS for members of the Board, who have noted that Cornell's applications seem to change over time, and that their promises to minimize the use of artificial turf on the Game Farm Road site should be made binding through a GEIS. This should be included in the record to clarify our position, and to clarify to the public why the women's field hockey team faces a deadline crunch. In her March 4 testimony before your Board, Cornell's applicant, Kimberly Michaels, incorrectly characterized the situation as one where "these young women...are caught in a bunch of politics." (~3:06:10). It would be more correct to state that these young women are caught in a timeline conflict created by Cornell's bad-faith SEQR segmentation request. Unfortunately, some members of your Board appear to misunderstand the situation themselves. One Board member took the surprising position that this field hockey project is being "scapegoated." We trust that the below clarification will ensure that Board members understand their role in upholding the integrity of the SEQR process, and that they will also ensure that Cornell does not violate the terms of SEQR segmentation with impunity. When your Board originally discussed Cornell's SEQR segmentation request in May 2024, Board members stated that SEQR segmentation would only be permissible if "future phases are functionally independent of current phases" (Bill Arms). That proved to be false. Your Board members also stated that they would support segmentation only if it did not interfere with the Board's ability to "give the project or the projects as much care and attention as it needs" (Cindy Kaufman). That will also prove to be false if the Board rushes this project through an expedited timeline under the emotional pressure of inconveniencing Cornell's field hockey season. We support athletics, including women's field hockey. We support healthy playing fields, a livable environment, and a Town Planning Board that upholds the integrity of SEQR law, even under political pressure. Thank you for considering this, and thank you for your continued attention to the integrity of SEQR law. take care, bethany ojalehto mays, PhD ---------- Forwarded message --------- From: bethany ojalehto mays <bethany.o.mays@gmail.com> Date: Sun, Mar 16, 2025 at 9:18 AM Subject: Correction to article on field hockey turf by Z. Faraj To: <managing-editor@cornellsun.com>, <zdf8@cornell.edu> Hello Julia and Zeinab, I'm writing to request a time-sensitive correction to the article written by Zeinab Faraj about the women field hockey's playing field, titled "‘A Monumental Blunder’: Million-Dollar Donor Baffled After Cornell Destroys Namesake Field Hockey Turf With No Immediate Replacement." In their Feb 26, 2025 article, Faraj writes that "Cornell had planned to relocate the field hockey team to a new location at Game Farm Road. However, the move has been set back. The delay in construction follows a series of complaints about environmental concerns from Ithaca residents over the proposed field’s use of synthetic turf." This is incorrect. The move has not been "set back." Instead, it is proceeding exactly as it should under the State Environmental Quality Review (SEQR) Act. Any project presented to the Planning Board must undergo an environmental assessment to determine whether or not there is the potential for at least one adverse environmental impact. If the Board finds that there is the potential for at least one adverse environmental impact, then a full environmental impact statement (EIS) is required. That EIS process may take months. It is the responsibility of all applicants, including Cornell, to plan for that likelihood when creating their project timeline. In the current case of the field hockey turf at Game Farm Road, the applicant (Cornell) was well informed that this particular project could rise to the level of an environmental impact statement (EIS). When Cornell's applicant, Kimberly Michaels, requested that the Town and City Planning Boards segment this project from Meinig Fieldhouse for purposes of environmental review last May, she was told by the Town Planning Board members that the Game Farm Road site "needs a very serious review...[and] is an interesting site from the SEQR point of view" (Bill Arms, at 41:10). Ms. Michaels also knew that two Town Planning Board members voted in favor of a positive declaration of environmental significance for the Meinig Fieldhouse project - a clear signal that they may do the same for the upcoming Game Farm Road Project. Therefore the applicant, Cornell, had every reason to expect that the Town Planning Board could find that the Game Farm Road project poses potential adverse environmental impacts requiring an EIS. Cornell should have planned their project timeline accordingly. Yes, an EIS may add months to a project's timeline: but it is by no means a "set back." It is an essential component of the State Environmental Quality Review Act put in place to protect our shared environment. It is the applicant's responsibility to plan multiple phases of a single project in a transparent way that allows the Planning Board to do their job properly: it is not the Planning Board's fault if Cornell failed to plan their projects transparently and responsibly. The fact is that Cornell (along with every other applicant who comes before the Board) should plan their projects with enough padding to allow time for an EIS, should that be required by the Board. Instead of doing so, Cornell chose to break up or "segment" what was clearly one athletics master plan project with one timeline into two smaller projects: the Meinig Fieldhouse Project and the Game Farm Road project. To do so, Cornell petitioned the Town and City Planning Boards to split their athletic master plan project into two smaller projects for purposes of environmental review, known as a "SEQR segmentation" request. Of course, these are not two separate projects, as your headline makes clear. That's exactly why Marsha Dodson is so angry. In order to make their segmentation case, then, Cornell had to misrepresent the facts. In May 2024, Cornell's applicant Ms. Michaels testified before the Town Planning Board that the Game Farm Road and Meinig Fieldhouse projects were "functionally independent," on "different timelines," only "mildly related," that "there is no relationship there" [between the two projects], and that the approval of the Meinig Fieldhouse "would not commit" the Town Planning Board to approve the Game Farm Road Project. These claims misrepresented the situation, as your article's headline and Marsha Dodson make clear. Athletics Director Nicki Moore herself conceded that these two projects are "interconnected" in her announcement to the Athletics Community cited in your article. This directly contradicts Cornell's SEQR-segmentation narrative that the two projects are "functionally independent" and "on different timelines." For details and documentation, please refer to my public comments on this topic submitted in December, January and February. Now, Cornell is pressuring the Town Planning Board to rush approval of their Game Farm Road project without a proper environmental review -- because Cornell misrepresented the fact that these two projects are not functionally independent and are not on different timelines. Does Cornell misrepresent the facts with impunity? This is not a mere technical issue: it gives the appearance of a strategic approach to misrepresenting the facts in order to evade proper environmental review. Why would Cornell want to segment these two projects for purposes of environmental review? Historically, this has often occurred in cases where the applicant wishes to evade scrutiny of the cumulative environmental impacts of a large action. One large project is more likely to trigger an EIS than two smaller projects. If the applicant can succeed in convincing the Planning Board(s) that their large project is actually two smaller ones for purposes of environmental review, then they can ensure that the cumulative impacts of the overall action are ignored. This is illegal. According to NY State Law: “If an action consists of multiple phases, sets of activities, or if separate agencies are involved, SEQR requires agencies jointly consider these cumulative impacts during their review. Segmentation of an action into smaller components for an individual review contradicts the intent of the law and may result in legal action.” To be perfectly clear: it is not the Town Planning Board's fault, or environmentalists' fault, if Cornell's proposed plan poses adverse environmental impacts that require an EIS that adds several months to the project's timeline. If Cornell chooses to design projects that pose potential adverse health and environmental consequences, then it is their responsibility and obligation to ensure that those projects are prepared to undergo full and appropriate environmental review. It is Cornell's responsibility to plan their athletic master plan project timeline in such a way as to allow for environmental law to be properly applied. For Faraj's article to characterize this as a "delay" caused by environmentalists and the Board is inaccurate. Unfortunately, your article replicates the false narrative that Cornell is trying to advance in order to inappropriately pressure the Town Planning Board to rush their inappropriately "segmented" project through approvals without a full environmental review. Cornell wishes to expedite this project so that they won't be inconvenienced by bussing student-athletes to Syracuse to play on the nearest regulation women's field hockey turf for part of a season. There was a clear legal path for Cornell to avoid this problem: they could have faithfully represented the "interconnected" nature of these two projects as one unified master plan, and sought environmental review for the entire project as a whole (including Meinig Fieldhouse and Game Farm Road). By taking this path, Cornell would have ensured that the women's existing field hockey turf was not destroyed without a replacement. Cornell chose not to do that, and instead chose to misrepresent the facts by seeking a bad-faith SEQR segmentation. I request that you correct this error and present the story in an accurate, balanced manner that correctly represents the letter and intent of the State Environmental Quality Review Act. This Tuesday's Town Planning Board meeting on 3/19 will be a decisive moment in this process that warrants your more informed and balanced coverage. Thank you. Sincerely, bethany ojalehto mays, PhD -- bethany ojalehto mays Cornell Alum & Former Assistant Professor Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins) Cornell on Fire | Mobilize Cornell to confront the climate emergency Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayog o̱hó꞉nǫ’ People (the Cayuga Nation). Land acknowledgements are only the first step toward reparations, restorative justice, and recognition. Understand more. "Do what is needed rather than what you want to do." -Vanessa Machado de Oliveira in Hospicing Modernity -- bethany ojalehto mays Cornell Alum & Former Assistant Professor Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins) Cornell on Fire | Mobilize Cornell to confront the climate emergency Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayog o̱hó꞉nǫ’ People (the Cayuga Nation). Land acknowledgements are only the first step toward reparations, restorative justice, and recognition. Understand more. "Do what is needed rather than what you want to do." -Vanessa Machado de Oliveira in Hospicing Modernity From: To: Cc: Subject: Sent: bethany ojalehto mays Town Of Ithaca Planning Chris Balestra Public comment submission 3/17/2025 6:54:26 PM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town Planning Board Staff and Members, I submit a public comment for consideration in advance of the Board's environmental determination on the Game Farm Road Project tomorrow. The requirement for clear evidence and documentation led to a long document, but I have summarized the main points and concerns in the 2-page letter of introduction. Thank you kindly for your careful consideration, and I look forward to seeing you tomorrow. take care, bethany -- bethany ojalehto mays Cornell Alum & Former Assistant Professor Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins) Cornell on Fire | Mobilize Cornell to confront the climate emergency Ithaca and Cornell lie on the traditional and contemporary homelands of the Gayogo̱hó꞉nǫ’ People (the Cayuga Nation). Land acknowledgements are only the first step toward reparations, restorative justice, and recognition. Understand more. "Do what is needed rather than what you want to do." -Vanessa Machado de Oliveira in Hospicing Modernity From: To: Cc: Subject: Sent: **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Regi Teasley Town Of Ithaca Planning Regi Teasley Science, plastic turf and Cornell University 3/17/2025 12:49:58 PM Members of the Town of Ithaca Planning Board, I want to alert you to a dynamic in the conversation about the artificial turf fields Cornell is proposing. You are regarding Cornell as a research university and center of higher learning. This is perfectly logical given its history. Unfortunately, they are becoming something different and, I believe, are using corporate strategies to muddy the waters and mislead us. If you doubt this, simply look closely at Cornell’s board members, their expertise, and their corporate ties. It’s a sorry state of affairs. We have been down this road before. Here is an example from the Tobacco companies and the debate about cancer. No doubt you can also find plenty of material about how fossil fuel companies have misled, even lied to us about fossil fuel use and climate change. You may find Cornell using some of their same language. Can we learn from these harmful experiences? Take a second look and scrutinize the information and the way in which it is being presented. Remember too, the centrality of the “Precautionary Principle,” where non-trivial harm is possible, do more careful research before accepting the project, product, etc. ———————————— 1953: “There is no proof that cigarette smoking is one of the causes [of lung cancer.]” In the 1950s, extensive studies from the United Kingdom and the United States . While it wasn’t the first time the correlation was explored, the public began to worry.Even researchers working for the tobacco industry appeared interested in the link. In a 1953 , one researcher noted that clinical data supported the theory that cigarettes could be cancer-causing.The tobacco industry had to respond to pointed to smoking as a likely cause of lung cancer confidential report for RJ Reynolds 1952 ad for Camel cigarettes reassure existing and potential customers. In 1954, tobacco companies in the U.S. released the “Frank Statement to Cigarette Smokers.” In the piece, the tobacco companies denied the link to cancer, stating: “We believe the products we make are not injurious to health.” They sought to cast doubt on the independent studies’ findings related to lung cancer, saying “There is no proof that cigarette smoking is one of the causes.” , however, that tobacco companies knew by the mid-1950s that their products were linked to cancer and were addictive. ——————- Regi Teasley Ithaca, NY ___________ Protect what is left, recover what is lost of the fair earth. William Morris, “Art and the Beauty of the Earth.” 1881 Research suggests Subject: The list of synthetic turf on Cornell campus, and Failing TenCate Turf March 17, 2025 Dear Town of Ithaca Planning Board Members, Cornell University is on track to have at least 9 synthetic turf fields—six existing, two under construction, and one proposed—plus at least one more planned at Game Farm Road according to the planning board discussions. Please find the list in the attached PDF. Without a legally binding Generic Environmental Impact Assessment (GEIS), even more could follow. Cornell claims they will limit the number of Game Farm Road Site synthetic turf "only" to 3, in the recent planning board presentations and documents. However, the university retains the power to expand at will without the binding GEIS. Their own 2015 document shows plans for six synthetic turf fields at the Game Farm Road site—bringing the total potential projected number of synthetic turf fields on campus to 12. This isn’t only a local issue—it’s part of a larger crisis where corporate interests override science and public health. See the recent Guardian article on microplastics' effect on crop production and global food supply. https://www.theguardian.com/environment/2025/mar/10/microplastics-hinder-plant-photosynthes is-study-finds-threatening-millions-with-starvation Peer-reviewed study referenced in the article: https://www.pnas.org/doi/abs/10.1073/pnas.2423957122 You may also find this 1-min video of failing TenCate turf in San Jose, California, from February 4, 2025, showing turf blades disintegrating only after 3 months of use, relevant for your decision for the SEQR determination. From the way it looks, stormwater filtration seems clearly insufficient for microplastics mitigation, as they do not seem to go through the drain. TenCate is the synthetic turf of choice by Cornell University for the field hockey field. Below are some photos from the video. Very little debris seem to go through the drain and the vast majority stays on the ground. Emily Jernigan Zero Waste Ithaca Treasurer Updated List of Synthetic Turf on Cornell University Campus as of March 11, 2025 Map: https://www.google.com/maps/d/u/1/edit?mid=1Vyg67BRoVsBxoQcd_m7Np4nsAdvN4PM&us p=sharing Cornell University is currently the largest source of synthetic turf microplastic pollution in Ithaca, with 8 existing, proposed, or under-construction synthetic turf fields. Cornell University is on track to have at least 9 synthetic turf fields—five existing, two under construction, one proposed, and at least one more planned at Game Farm Road - and potentially more. In comparison, Ithaca College has two, the Ithaca City School District has one, the Groton School District has one, and the Lansing School District has a proposed field still under debate. Cornell’s Long Range Vision Plan (April 2024) proposes five additional fields around Game Farm Road (see screenshot below with added markings). In its February 18 presentation to the Town Planning Board, Cornell claimed there would be “only three” of them at the Game Farm Road site would be synthetic turf. However, without a General Environmental Impact Statement (GEIS), there is no legal mechanism to hold them accountable to this claim, leaving them free to change course. At the January 7 and March 4 Town Planning Board meetings, Cornell attempted to discredit Zero Waste Ithaca’s submissions and bibliography by demonstrably misrepresenting science. They dismissed ZWI members' estimates of synthetic turf expansion on Cornell campus and public concerns as "untruths" and even accused us of spreading lies. We categorically reject these baseless claims. Our numbers are grounded in publicly accessible data, and our goal remains the same: to expose the environmental justice consequences of synthetic turf proliferation and demand transparency and accountability from Cornell University by demanding cooperation with GEIS. From page 7 of Cornell University: Game Farm Road Athletic Complex Facilities Master Plan (Ithaca, NY: Cornell University, June 2015), the plan originally included 6 synthetic turf fields at the Game Farm Road site. This would have brought the total number of synthetic turf fields on Cornell's campus to 12. Cornell now claims there will be “only” three synthetic turf fields at the Game Farm Road site in an obscure Town Planning Board document, but without a General Environmental Impact Statement (GEIS), there is no guarantee that Cornell will adhere to this projection. From https://fcs.cornell.edu/sites/default/files/imce/site_contributor/Dept_University_Architect_and_C ampus_Planning/documents/Campus_Planning/Game%20Farm%20Road%20Athletic%20Comp lex%20Facilities%20Master%20Plan.pdf Currently Existing Synthetic Turf Fields: 1. Hoy Field (2007) – Baseball (Demolished in 2023, but as of March 11, 2025, Cornell University still lists it as an existing facility. This outdated information on Cornell’s website led to an incorrect count in our earlier submission.) https://en.wikipedia.org/wiki/Hoy_Field https://cornellbigred.com/facilities/hoy-field/5 2. Schoellkopf Field (1979) – Football, Lacrosse, etc. https://en.wikipedia.org/wiki/Schoellkopf_Field 3. North Campus Turf Field (2022) – Recreation https://scl.cornell.edu/recreation/north-campus-turf-field https://news.cornell.edu/stories/2022/08/cornell-welcomes-students-marks-milestone-resi dential-life 4. Booth Field (2023) – Baseball, Game Farm Road https://cornellbigred.com/facilities/booth-field/2132 5. Niemand-Robison Softball Field (1998) – Softball https://cornellbigred.com/facilities/niemand-robison-softball-field/13 6. Ramin Multipurpose Room – Indoor synthetic turf, Bartels Hall https://cornellbigred.com/facilities/ramin-multipurpose-room/73 Proposed/Under Construction Synthetic Turf Fields: 7. Meinig Fieldhouse (Under Construction) – Indoor synthetic turf, planned to use crumb rubber https://www.cityofithaca.org/DocumentCenter/Index/1647 8. Adjacent Synthetic Turf Field to Meinig Fieldhouse (Under Construction) –Name unknown, described as using "PFAS-free" organic infill, though many questions and concerns raised in previous public comments remain poorly answered by Cornell https://www.cityofithaca.org/DocumentCenter/Index/1647 9. Field Hockey Field, Game Farm Road (Currently Proposed) – no infill https://lfweb.tompkins-co.org/WebLink/Browse.aspx?id=357756&dbid=9&repo=TownO fIthaca&cr=1 *** Five additional fields proposed around Game Farm Road in Cornell’s “Long Range Vision Plan” (April 2024, Page 6) submitted to the City and Town Planning Boards, of which “only” three will be synthetic turf. There is a plan for at least one more synthetic turf at the site, according to Cornell’s recent submissions to the Town Planning Board in February 2025. There could be even more without legally binding GEIS. https://www.dropbox.com/scl/fi/fg4n5fanrv3o2xwf6dli5/PB-packet-5-21-24-Meinig-SEQ R-Segmentation-Long-Range-Vision.pdf?rlkey=1lq70pmm1q3ie7s4yn5z073my&st=87q gj6qr&dl=0 From: To: Subject: Attachments: Sent: Yayoi Koizumi Town Of Ithaca Planning; pbstaﬀ@cityoﬁthaca.org; Submission of Two Bibliographies on Synthetic Turf Impacts Selection from ZWI Synturf Bibliography for Field Hockey Field on Game Farm Road Site-1.pdf 3/18/2025 8:07:52 AM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town of Ithaca Planning Board Members, We are submitting two bibliographies for the Town of Ithaca Planning Board's review regarding synthetic turf and its environmental and health impacts. These materials provide comprehensive, science-based evidence that contradicts claims made regarding the proposed synthetic turf field at Game Farm Road and the broader concerns surrounding artificial turf use. 1. Comprehensive Bibliography (162 pages, Updated March 17, 2025) This fully categorized, partially annotated bibliography has been meticulously compiled over the past year by volunteers and allies across the country. It presents a multifaceted analysis of synthetic turf, covering: Plastic life cycle impacts PFAS in all components of artificial turf system and industry's misleading ‘PFAS-free’ claims Independent PFAS test results Toxicity beyond PFAS: heavy metals, plasticizers, and other chemicals Synthetic turf fiber loss and microplastic pollution Health risks: injuries, heat exposure, air emissions Environmental justice impacts throughout plastic lifecycle: plastic pollution in urban and rural communities Disposal issues and the failure of plastic recycling at scale Legislative bans, restrictions, moratoriums, lawsuits, and investigative journalism Cost comparisons and heat island effects between natural grass and artificial turf Video documentation of visible synthetic turf degradation and microplastic pollution, relevant webinars with experts Despite the overwhelming body of evidence, Cornell’s submission to the Town of Ithaca Planning Board selectively excluded or downplayed key findings by focusing only on peer-reviewed studies while disregarding highly relevant materials from independent experts, nonprofit organizations, and investigative journalists. We strongly urge Town Planning Board members to review this bibliography thoroughly, or at the very least skim through its key sections to understand the depth and breadth of the issue. This collection represents a year’s worth of dedicated research, carefully selected and organized, and it deserves serious consideration. 2. Selected Bibliography on Turf Fibers and "PFAS-free" Claims (15 pages, Updated March 17, 2025) This second bibliography focuses specifically on synthetic turf fibers, backings and shockpads, particularly regarding the Game Farm Road field, which has been described as “safe” in part due to the absence of crumb rubber infill. However, as the scientific evidence clearly shows, synthetic turf blades and backings are significant sources of toxic microplastic pollution, including: PFAS contamination in turf fibers Microplastic and chemical leaching from synthetic grass blades Long-term degradation of turf fibers, contributing to environmental pollution Cornell’s submission has framed the absence of crumb rubber infill as evidence that there are no significant concerns with the proposed field. However, this misrepresents the broader body of research showing that turf fibers and backings themselves contain hazardous chemicals and contribute to ongoing environmental pollution. The evidence compiled in this 13-page fully annotated bibliography challenges these claims and provides clear scientific proof that synthetic turf— regardless of infill—poses serious environmental and health risks. Cornell’s Handling of Scientific Studies Cornell’s submission to the Town Planning Board excluded or downplayed important studies that challenge the claims made in favor of synthetic turf. For example: Key studies were omitted or misrepresented in the 39-page submission despite clear relevance. Some studies were dismissed as “non-peer-reviewed” even when they contained credible scientific data. Other studies were labeled “not turf-specific” despite clear findings on synthetic turf pollution. Certain studies were included in name only, with just an abstract copied into the submission rather than an engagement with the findings. We find it ironic that Cornell representatives, such as Kimberly Van Leeuwen (formerly Kimberly Michaels), have told the Town Planning Board to “look at the original studies.” in the March 4 Town Planning Board meeting. We strongly encourage board members to do exactly that, because these studies expose patterns of selective omission and downplaying of environmental and public health risks. Conclusion & Call to Action The Town Planning Board has a responsibility to critically evaluate all available evidence before making decisions that will impact the local environment and public health. Given the significant body of research indicating environmental and health concerns, these risks deserve thorough and independent consideration. We urge board members to: 1. Thoroughly review the 15-page Selected Bibliography focused on turf fibers and backings. 2. Examine the 162-page Comprehensive Bibliography to understand the broader issue. 3. Consider how certain studies have been selectively omitted or dismissed— specific examples are highlighted in our materials. Final Note The synthetic turf industry has long used selective data and marketing to downplay concerns. We hope that the Town Planning Board will take an independent, science- based approach, rather than relying solely on the claims made in favor of synthetic turf. We respectfully ask the Town Planning Board to approach these materials with the critical scrutiny they deserve and to recognize that the Game Farm Road field poses serious environmental risks—even without crumb rubber infill. In compiling the Selected Bibliography, we specifically examined how Cornell University represented and omitted key materials related to turf blade degradation, PFAS testing, and the industry’s claims of PFAS-free synthetic turf in their 39-page submission to the Town Planning Board. However, this is only a fraction of their submission that we had time to analyze as volunteers. While this selection highlights clear patterns of omission and misrepresentation, it reflects a broader ongoing pattern that we have already documented in previous submissions regarding CY Jim, Zuccaro, EPA reports, and on plastic recycling numbers. We respectfully submit this as further evidence of the systematic dismissal of key findings and urge the Planning Board to review these materials with scrutiny. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Yayoi Koizumi Yayoi Koizumi Zero Waste Ithaca | BYO - US Reduces Founder | Co-Founder zerowasteithaca.org usreduces.org 1 Toxic Chemicals and Microplastic Pollution in Synthetic Turf Blades, Backings, and Runoff Filtration Selected Materials for the Call on GEIS for the Game Farm Road Site from: The Case Against Artificial Turf Expansion at Cornell: A Zero Waste Ithaca Bibliography, Updated March 16. 2025 https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM- s_4bfbmO26R-Q/edit?tab=t.0 This bibliography focuses on the toxic chemicals and microplastic pollution associated with artificial turf blades, backings, and runoff filtration—not just infill. Cornell University has attempted to dismiss environmental and health concerns by claiming that because the planned field hockey field does not include crumb rubber infill, it poses no risks. However, research shows that synthetic turf blades and backings contain and shed hazardous substances, including PFAS, phthalates, heavy metals, and microplastics, which persist in the environment and pose health risks. The studies and reports compiled here provide evidence that synthetic turf fields—regardless of infill—are a significant source of microplastic pollution and chemical exposure. Note on Bibliographic Items and Cornell's Omissions Certain key sources in this bibliography have been misrepresented, dismissed, or entirely omitted in Cornell’s 39-page table submitted to the Town of Ithaca Planning Board in their February 21, 2025 submission of “Supplemental Materials Submission.” Their categorization tactics include: ● (*) Omission – Conveniently left out from Cornell’s submission despite relevance. ● (**) Dismissal as "Non-Peer Reviewed" – Used as a reason to disregard findings. ● (***) Misrepresentation – Included only as a copied abstract with no discussion to repudiate study findings or misrepresent findings. ● (****) Dismissal as "Not Turf Specific" – Ignoring connections to artificial turf pollution. This selection presents a full, unfiltered view of the scientific literature, including materials Cornell has attempted to discredit. While we have not had time to analyze all omissions from our 150+-page bibliography, this document highlights key sources relevant to the Planning Board’s review of the infill-free, water-based field hockey field at the Game Farm Road site. These materials directly counter Cornell’s claims by demonstrating that pollution from artificial turf extends beyond infill and includes microplastic shedding, PFAS contamination, and toxic chemical leaching from the blades and backings themselves. 2 Toxic Substances and Microplastic Shedding from Artificial Turf Blades and Backings **Abel, David. "Toxic Chemicals Are Found in Blades of Artificial Turf." Boston Globe, October 9, 2019. Available at https://www.bostonglobe.com/metro/2019/10/09/toxic-chemicals-found-blades-artificial-t urf/1mlVxXjzCAqRahwgXtfy6K/story.html. *California Department of Toxic Substances Control. Background Document on Candidate Chemicals in Artificial Turf. Safer Consumer Products Program, California Environmental Protection Agency, August 2024. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Cand idate-Chemicals-in-Artificial-Turf.pdf. The California Department of Toxic Substances Control (DTSC) released the "Background Document on Candidate Chemicals in Artificial Turf" in August 2024. This document examines the presence of per- and polyfluoroalkyl substances (PFASs), ortho-phthalates, and other additives in artificial turf blades and backing. It highlights concerns regarding potential human and environmental exposures to these chemicals and seeks public input to address data gaps and inform future regulatory actions. In response to this call for public comments, Diana Conway from Safe Healthy Playing Fields and the Silent Spring Institute submitted a letter expressing concerns about the presence of PFAS and other toxic chemicals in artificial turf. They urged the DTSC to take regulatory action to protect public health and the environment from hazardous exposures associated with synthetic playing surfaces. Following the public comment period, which concluded on September 30, 2024, the DTSC held a virtual workshop on August 27, 2024, to discuss key findings and gather additional input. The information collected from the workshop and public comments is being used to prioritize candidate chemicals in artificial turf for potential regulation. As of February 2, 2025, the DTSC is conducting further research to draft a Product-Chemical Profile document for artificial turf containing PFAS. This ongoing research aims to inform potential regulatory actions to mitigate adverse public health and environmental impacts associated with these chemicals. *** De Haan, William P., Rocío Quintana, César Vilas, Andrés Cózar, Miquel Canals, Oriol Uviedo, and Anna Sanchez-Vidal. “The Dark Side of Artificial Greening: Plastic Turfs as Widespread Pollutants of Aquatic Environments.” Environmental Pollution 334 (2023): 122094. https://doi.org/10.1016/j.envpol.2023.122094. 3 This Barcelona study found that up to 15% of the larger microplastic pieces in the environment come from artificial turf blades. This significant fiber loss contributed to the University of California, Santa Barbara's decision to choose natural grass over artificial turf, supported by the California Coastal Commission, on December 13, 2023. De Haan's presentation in a CHE webinar in September 2024 emphasized there must be more than 15% but there was no viable method available to test smaller particles. Hann, S., C. Sherrington, O. Jamieson, M. Hickman, P. Kershaw, A. Bapasola, and G. Cole. Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics Emitted by (but Not Intentionally Added in) Products. Bristol, UK: Eunomia Research & Consulting, 2018. https://eunomia.eco/reports/investigating-options-for-reducing-releases-in-the-aquatic-en vironment-of-microplastics-emitted-by-products/. This report, commissioned by the European Commission, examines various sources of microplastic pollution, including artificial turf fields. It estimates that a single synthetic turf field loses 0.5 to 0.8% of its plastic blades annually, equating to approximately 2,000 to 3,000 pounds of microplastic pollution per field per year. This estimate, significantly lower than a previous Danish study's 0.8 kg/m² loss rate, highlights the ongoing and substantial contribution of synthetic turf fiber to environmental microplastic contamination. The report provides direct evidence that plastic blade fragmentation is an unavoidable and underestimated source of pollution. *** Lauria, Mélanie Z., Ayman Naim, Merle Plassmann, Jenny Fäldt, Roxana Sühring, and Jonathan P. Benskin. “Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from Stockholm, Sweden.” Environmental Science & Technology Letters. July 6, 2022. DOI: 10.1021/acs.estlett.2c00260 https://pubs.acs.org/doi/10.1021/acs.estlett.2c00260 Lauria et al. (2022) found that artificial turf fibers in Stockholm contain polymeric PFAS, including fluoroelastomers and polytetrafluoroethylene (PTFE), which are highly persistent and resistant to degradation. The study highlights that incineration is ineffective at fully breaking down these compounds, potentially leading to the release of toxic fluorinated byproducts such as hydrogen fluoride and perfluoroalkyl acids (PFAAs). Additionally, artificial turf blades degrade over time, shedding PFAS-laden microplastics that disperse into the environment, contributing to soil and water contamination. Exposure to UV light, heat, and mechanical stress can break down polymeric PFAS into smaller, more mobile and toxic perfluoroalkyl carboxylic acids (PFCAs), such as PFOA, which are known to bioaccumulate. The findings underscore that artificial turf serves as a long-term source of PFAS pollution, with no viable disposal method that prevents environmental contamination. *** Mehmood, Tariq, and Licheng Peng. "Polyethylene Scaffold Net and Synthetic Grass Fragmentation: A Source of Microplastics in the Atmosphere?" Journal of Hazardous Materials 429 (May 2022): 128391. https://doi.org/10.1016/j.jhazmat.2022.128391 4 Mehmood and Peng explore the growing concern surrounding microplastics (MPs) in urban atmospheres, particularly focusing on polyethylene (PE), which dominates ambient MPs in China’s megacities. They investigate the sources of airborne PE, such as scaffold netting and synthetic grass fiber/blades used in construction and land covering. These materials, often made from recycled plastic and exposed to open air, are prone to degradation and fragmentation, contributing to atmospheric pollution. The authors emphasize the health risks associated with PE exposure in urban air and highlight the need for regulation to mitigate these risks. This study offers insights into the overlooked role of synthetic grass and construction materials as significant contributors to airborne microplastics. *** Mohammed, Atef MF, Inas A. Saleh, and Nasser M. Abdel-Latif. “Hazard Assessment Study on Organic Compounds and Heavy Metals from Using Artificial Turf.” Heliyon 9, no. 4 (2023). https://www.cell.com/heliyon/pdf/S2405-8440(23)02135-7.pdf. The Egyptian study investigates the release of hazardous substances, including VOCs, PAHs, and heavy metals, from artificial turf as affected by sunlight exposure. It monitors VOC levels across different seasons and settings, including indoor and outdoor environments. The findings indicate elevated VOC levels during warmer seasons and highlight higher exposure risks for younger age groups (7–15 years) compared to others. While the hazard index (HI) values suggest no immediate non-carcinogenic risk, the study reports a high probability of cancer risk (R) for various age groups, particularly children, when exposed to artificial turf on football fields. Cornell falsely dismissed Mohammed et al. (2023) in their table (Item 81) as a study solely on tire-derived crumb rubber (TDCR) when it actually examined VOCs, PAHs, and heavy metals from all components of synthetic turf under different environmental conditions. They selectively cited the study’s non-carcinogenic risk (HI < 1) while omitting its key finding that the carcinogenic risk (R) exceeded safety thresholds, particularly for children aged 7–15. Cornell also ignored the study’s clear evidence that VOCs increase significantly in warm weather, making exposure risks higher during peak usage seasons. Their misrepresentation distorts the study’s conclusions, downplays health risks, and falsely narrows its scope to avoid acknowledging the cancer risks and broader toxicity of synthetic turf. ** Persellin, Ketura. “New Studies Show PFAS in Artificial Grass Blades and Backing.” Environmental Working Group. October 29, 2019. https://www.ewg.org/news-insights/news/new-studies-show-pfas-artificial-grass-blades-a nd-backing. * Ryan-Ndegwa, Sebastian, Reza Zamani, and Tanimola Martins. "Exploring the Human Health Impact of Artificial Turf Worldwide: A Systematic Review." Environmental Health Insights, first published online December 17, 2024. https://doi.org/10.1177/11786302241306291. This systematic review examines the potential human health risks associated with 5 artificial turf, focusing on polycyclic aromatic hydrocarbons (PAHs), heavy metals, and rubber additives. Hazardous chemical concentrations were detected in artificial turf fibers and crumb rubber infill, necessitating further research. *** Simpson, Thomas J., and Robert A. Francis. “Artificial Lawns Exhibit Increased Runoff and Decreased Water Retention Compared to Living Lawns Following Controlled Rainfall Experiments.” Urban Forestry & Urban Greening 63 (2021): 127232. https://doi.org/10.1016/j.ufug.2021.127232. This study examines the hydrological impacts of artificial (synthetic polymer) grass compared to living grass using controlled rainfall experiments. It finds that artificial grass, especially with longer pile heights, produces greater runoff and sheds plastic thatch and fibers, posing environmental concerns; living grass demonstrates superior water retention and drainage control. ** Wittenberg, Ariel and E. A. Crunden. “EPA-Linked Consultant Undercuts Agency’s PFAS Concerns.” Politico E&E News. December 8, 2021. https://www.eenews.net/articles/epa-linked-consultant-undercuts-agencys-pfas-concerns. Laura Green, an industry toxicologist promoting artificial turf fields has repeatedly cited her work for EPA while downplaying the risks of “forever chemicals” while showing the evidence the chemicals are used to produce plastic grass blades, making controversial claims often at odds with the agency’s own findings. * Zhang, Xiaoran, Yupeng Gu, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, Ziyang Zhang, Chaohong Tan, Yu Wang, and Haiyan Li. “Occurrence and Risk Assessment of PAHs from Athletic Fields under Typical Rainfall Events.” Water Science & Technology 87, no. 9 (2023): 2159–2171. https://doi.org/10.2166/wst.2023.092. This study examines the release of PAHs from various athletic field surfaces during rainfall, finding significantly higher PAH concentrations in runoff from artificial turf compared to other surfaces. While PAHs are often associated with crumb rubber infill, research has shown that PAHs can also be present in turf blades and backings due to manufacturing additives, plasticizers, recycled plastics and carbon black. This is critical because Cornell’s claim of using plant-based infill for some outdoor turf does not address the contamination risks posed by the synthetic turf itself. *** Zuccaro, Philip, James Licato, Emily A. Davidson, David C. Thompson, and Vasilis Vasiliou. “Assessing Extraction-Analysis Methodology to Detect Fluorotelomer Alcohols (FTOH), a Class of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), in Artificial Turf Fibers and Crumb Rubber Infill." Case Studies in Chemical and Environmental Engineering 7 (2023): 100280. https://doi.org/10.1016/j.cscee.2022.100280. This pilot study developed and applied an adapted extraction-analysis method to detect fluorotelomer alcohols (FTOHs), a class of PFAS, in artificial turf fibers and crumb 6 rubber infill. Results revealed the presence of 8:2 FTOH at concentrations of 300 ng/g in turf fibers and 110 ng/g in crumb rubber, emphasizing the need for further research into PFAS in artificial turf components. On “PFAS-Free” Claim by Synthetic Turf Manufacturers ** Gambacorta, David and Laker, Barbara. “City Officials Believed a New South Philly Turf Field was PFAS-Free. Not True, Experts Say.” The Philadelphia Inquirer. February 23, 2024. https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-turf-field-murph y-recreation-20240223.html This article is a part of the multi-year investigative journalism on synthetic turf by The Philadelphia Inquirer. The industry’s “PFAS-free” claims turned out to be false for a new Philadelphia turf field. ** Gearhardt, Jefferey, MS. Director of Research, The Ecology Center, Ann Arbor, MI. Letter to Portsmouth, NH City Council and Director of Finance and Administration. 1 Jun 2020. https://nontoxicdovernh.files.wordpress.com/2020/06/june1_portsmouthpfas.pdf This letter, addressed to the Portsmouth City Council, discusses the challenges of accurately testing for PFAS in synthetic turf fibers. The author reports that, despite claims of PFAS-free turf, their research detected fluorine, a potential indicator of PFAS, in all nine synthetic turf fibers tested. One sample from the Tom Daubney Field in Portsmouth showed 79 parts per million (ppm) of fluorine, indicating the likely presence of PFAS, despite PFAS-free claims. The letter highlights concerns about the inadequacy of EPA Method 537.1, which is designed for water testing and does not detect all possible PFAS chemicals. The author advocates for more comprehensive testing methods to ensure accurate PFAS detection in synthetic turf. ** Kristen Mello, MS. Email to Mayor Eachern, City of Portsmouth, NH Regarding Additional PFAS Testing of FieldTurf Vertex, Schmidt Shock Pad and SafeShell infill installed June 2021. July 5, 2022. https://nontoxicdovernh.wordpress.com/wp-content/uploads/2022/07/wraft-pfas-portsmo uthletter-5july2022.pdf The letter by Kristen Mello, M.Sc. in Analytical Chemistry, addresses concerns about PFAS contamination in synthetic turf materials, specifically referencing testing results 7 from Portsmouth, New Hampshire. It details the findings of both known and unidentified PFAS compounds in various components of artificial turf, such as the Field Turf carpet, Schmitz Foam ProPlay pad, and Greentech Safeshell infill, with results showing the presence of multiple toxic chemicals including GenX, HFPO-DA, and other proprietary PFAS. These findings contradict industry claims that certain turf products are "PFAS free." The letter highlights the potential risks to public health and the environment, emphasizing the need for strict oversight and accountability from city officials, especially in holding contractors responsible for their promises of PFAS-free materials. In light of EPA advisories that drastically reduce acceptable PFAS exposure levels, the letter urges city officials to take every measure to limit contamination and protect taxpayers from future costs related to turf field replacement, remediation, and disposal. *** Lauria, Mélanie Z., Ayman Naim, Merle Plassmann, Jenny Fäldt, Roxana Sühring, and Jonathan P. Benskin. “Widespread Occurrence of Non-Extractable Fluorine in Artificial Turfs from Stockholm, Sweden.” Environmental Science & Technology Letters. July 6, 2022. DOI: 10.1021/acs.estlett.2c00260 https://pubs.acs.org/doi/10.1021/acs.estlett.2c00260 Lauria et al. (2022) found that artificial turf fibers in Stockholm contain polymeric PFAS, including fluoroelastomers and polytetrafluoroethylene (PTFE), which are highly persistent and resistant to degradation. The study highlights that incineration is ineffective at fully breaking down these compounds, potentially leading to the release of toxic fluorinated byproducts such as hydrogen fluoride and perfluoroalkyl acids (PFAAs). Additionally, artificial turf blades degrade over time, shedding PFAS-laden microplastics that disperse into the environment, contributing to soil and water contamination. Exposure to UV light, heat, and mechanical stress can break down polymeric PFAS into smaller, more mobile and toxic perfluoroalkyl carboxylic acids (PFCAs), such as PFOA, which are known to bioaccumulate. The findings underscore that artificial turf serves as a long-term source of PFAS pollution, with no viable disposal method that prevents environmental contamination. Cornell misrepresents Lauria et al. (Item 37 in the table) by selectively emphasizing that the study found low levels of extractable PFAS while ignoring its broader environmental concerns. While the study states that most fluorine in artificial turf exists in polymeric form and does not pose an imminent risk to users, Cornell downplays Lauria’s warnings about long-term environmental contamination, including microplastics and the unknown effects of fluoropolymer degradation. Additionally, Cornell overlooks Lauria’s findings on the potential risks associated with artificial turf’s disposal, as landfilling and incineration may release PFAS into the environment. By focusing solely on the low bioavailability of PFAS in the short term, Cornell mischaracterizes the study’s overall conclusions, which explicitly call for further research into the long-term impacts of PFAS-containing artificial turf. 8 ** Rudiman, M, LaRossa, S. Response to Questions, Synthetic Turf Installation, Portsmouth, NH. Weston and Sampson Email Communication to S Woodward and P Rice, City of Portsmouth, NH with Response from Manufacturer FieldTurf (a Tarkett Company) Regarding Claims of PFAS Free Synthetic Turf. November 5, 2021. https://www.dropbox.com/scl/fi/pr5t7p34hlndd1lk3tlyj/PFAS_Questions-Letter-Portsmou th-11.05.21.pdf?rlkey=7tk69p1vaqx7x6r0bc9fb7eot&st=t443mr9c&dl=0 Weston & Sampson Engineers, Inc. respond to questions from Diana Carpinone regarding the synthetic turf field installation in Portsmouth, New Hampshire. The letter confirms that FieldTurf, the manufacturer of the synthetic turf, incorrectly claimed its product was "Fluorine Free." While the product met the project’s specifications for being PFAS-free based on existing standards, the letter acknowledges the possibility of fluorine presence in the natural environment and emphasizes the limitations of current testing technologies. The company conducted PFAS testing using EPA Method 537.1, but did not verify whether specific PFAS polymers, such as PTFE or PVDF, were used. This correspondence highlights the complexities and gaps in testing for fluorine-based compounds in synthetic turf materials. ** Toxic Use Reduction Institute. “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet.” February 2020. https://www.turi.org/publications/pfas-in-artificial-turf-carpet/ This nonprofit report addresses the challenges in testing for PFAS (Per- and Polyfluoroalkyl Substances) in artificial turf and other solid materials. It highlights the difficulty of detecting the full range of PFAS due to the vast number of chemicals in the class and the limitations of current testing methods, which are primarily developed for water rather than solid materials. The report suggests that the industry's claims of "PFAS-free" products can be misleading, as the absence of specific PFAS in tests does not confirm the absence of all PFAS. The use of Total Fluorine Analysis and TOP assays is recommended for a broader understanding of PFAS presence. Additionally, the report cites research that detected PFAS in artificial turf fibers and backing, including both short-chain and long-chain PFAS, raising concerns about their environmental impact and health risks. * Whitehead, Heather D. Development of Analytical Methods for Highly Selective and Sensitive Analysis of Compounds Relevant to Human Health and the Environment. PhD diss., University of Notre Dame, 2023. https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Se lective_and_Sensitive_Analysis_of_Compounds_Relevant_to_Human_Health_and_the_ Environment/24869502?file=43760148. Dropbox full pdf backup: https://www.dropbox.com/scl/fi/73xaku3dwi0jjtgamnoe3/WhiteheadHD042023D-1.pdf?r lkey=y871tnevcqk4r0kwlzd42qhke&st=ioc6xn65&dl=0. This dissertation provides critical evidence of PFAS contamination in artificial turf blades, analyzing 27 samples using multiple methods. PFAS were detected in all samples, with a median concentration of 5.1 ng/g and a maximum of 41.7 ng/g, while 9 organic fluorine measurements indicated the presence of fluorinated polymer processing aids. This is arguably the most in-depth scientific study on PFAS in artificial turf blades that Cornell University conveniently omits from their 39-page table detailing our bibliographic entries to discredit them. These findings confirm that PFAS are embedded in synthetic turf materials, raising concerns about long-term environmental and human exposure risks. Cornell dismisses critical research by Peaslee & Whitehead (2024) as "non-peer-reviewed" (line item 85) despite its direct relevance to PFAS contamination from synthetic turf runoff. At the same time, they conveniently fail to include Whitehead’s 2023 Ph.D. dissertation, which is arguably the most in-depth scientific study to date on PFAS in synthetic turf blades. Whitehead (2023) analyzed 27 artificial turf samples, detecting PFAS in every single one using multiple analytical methods, with concentrations ranging from 5.1 ng/g to 41.7 ng/g. The omission of this study is indefensible and further underscores their selective cherry-picking of studies that align with their predetermined conclusions. In addition to peer-reviewed research, independent testing has repeatedly found PFAS in both synthetic turf blades and backings, contradicting manufacturers’ claims of "PFAS-free" products. These independent analyses suggest that fluorinated polymer processing aids (fPPAs), used in plastic extrusion, likely introduce PFAS into turf materials. The industry's claims of PFAS-free certification remain unverified by independent scientific scrutiny. Cornell’s approach demonstrates a pattern of misrepresentation and omission, selectively dismissing robust studies that document PFAS contamination in synthetic turf while inflating the credibility of studies that support their narrative. The exclusion of Whitehead (2023), in particular, is a glaring omission that calls into question the integrity of their entire submission. 10 Turf Blade Deterioration Videorecordings Documented by Grassroots Volunteers Around the US Bond, Pamela. John Mise Park, San Jose, California: TenCate Pivot. February 4, 2025. https://www.dropbox.com/scl/fi/naamke5hbco8pt82zw843/TenCate-Pivot-turf-John-Mise -Park-San-Jose-CA-only-3-months-after-installation-video-by-Pam-Bond-of-Los-Gatos- CA-Feb-4-2025.qt?rlkey=fz31t8t2pmx6sjtxgwee5oyt1&st=hvktv3mn&dl=0 TenCate is Cornell’s chosen synthetic turf manufacturer for the planned field hockey field on Game Farm Road. This one-minute video documents visible fragmentation and failure of TenCate's synthetic turf blades at John Mise Park in San Jose, California, occurring just three months after installation. The footage demonstrates turf blades breaking into smaller fibers, which disperse into the environment rather than being captured by the filtration system intended to prevent microplastic pollution. Recorded on February 4, 2025, by Pamela Bond, a resident of Los Gatos, California, concerned about environmental impacts of synthetic turf. 11 * Farber, Amanda. Synthetic Turf Fields Are Failing. YouTube video, 5:26. September 2018. https://www.youtube.com/watch?v=iV-Mh_q0gMI&t=4s. Amanda Farber, a member of Safe Healthy Playing Fields, documents the deterioration of synthetic turf fields in Washington, D.C., with footage from August and September 2018. The video highlights the visible breakdown of artificial grass blades and infill displacement, underscoring concerns about the durability and safety of these fields. * Safe Healthy Playing Fields. Artificial Turf Hearing - Dr. Laura Green. YouTube Video. April 13, 2021. https://youtu.be/A8OLBfWmt7g?si=DfSEWqdt6YemE-ER * Safe Healthy Playing Fields. [Turf Blade Deterioration at Rotch Field at Emerson College, Boston.] July 10, 2021. https://www.facebook.com/share/v/19zktsiY6Q/?mibextid=wwXIfr * Safe Healthy Playing Fields. [Turf Blade Deterioration at Walter Johnson High School in Bethesda, MD.] July 26, 2019. https://www.facebook.com/share/v/19zApLLE6k/?mibextid=wwXIfr * Safe Healthy Playing Fields. [Turf Blade Deterioration at MIT, Boston.] July 25, 2021. https://www.facebook.com/share/v/1DxUuEDeTE/?mibextid=wwXIfr 12 * Woelke, Dianne. [Turf Blade Deterioration at Villa Parke]. Filmed June 2024 at Villa Parke, Pasadena, CA. https://www.dropbox.com/scl/fi/55qmokb3cgpqebcnwy95m/73983745599__0E158EA2-7 E22-467E-976A-065BF7A21B51.mov?rlkey=k04cfu2480126zzuvn0kitpgy&st=ffep4pi4& dl=0. In this video, Dianne Woelke, a board member of Safe Healthy Playing Fields, documents the degradation of 1.5 year-old FieldTurf brand artificial turf at Villa Parke in Pasadena, California. The footage, captured in June 2024, highlights issues such as turf blades detaching and infill displacement, raising concerns about the durability and safety of synthetic playing surfaces. Filtration of Runoffs **** Brown, Erina, Anna MacDonald, Steve Allen, Deonie Allen. “The Potential for a Plastic Recycling Facility to Release Microplastic Pollution and Possible Filtration Remediation Effectiveness.” Journal of Hazardous Materials Advances. May 2023. https://doi.org/10.1016/j.hazadv.2023.100309 The UK study shows that the filtration system installed at the plastic recycling facility is effective at removing the majority of microplastics larger than 5µm, with particularly high removal efficiencies for those larger than 40µm. However, the filtration is ineffective at removing microplastics smaller than 5µm, which are subsequently discharged into the environment. The recommendation for additional filtration indicates that the current system does not adequately address all microplastic pollution, particularly the smaller particles. **** Chand, Rupa, Lucian Iordachescu, Frida Bäckbom, Angelica Andreasson, Cecilia Bertholds, Emelie Pollack, Marziye Molazadeh, Claudia Lorenz, Asbjørn Haaning Nielsen, and Jes Vollertsen. "Treating Wastewater for Microplastics to a Level on Par with Nearby Marine Waters." Water Research 256 (June 1, 2024). https://doi.org/10.1016/j.watres.2024.121647. The Swedish study conducted at a wastewater treatment plant focuses on the retention of microplastics ranging from 10 to 500 µm. The plant's filtration system, which achieved a 99.98% removal efficiency, utilizes a combination of mechanical, biological, and chemical treatments, and includes rapid sand filtration with pore sizes ranging from 15 to 30 µm—much smaller than the 212-micron pore size for Meinig “Fieldhouse” Project and 25-micron for Field Hockey Field on Game Farm Road Site proposed by Cornell’s filtration system. Their success is due to the integration of multiple processes, rather than relying solely on mechanical filtration. However, it's important to note that this study did not target or remove sub-micron nanoparticles, which the Korean TENG study addressed using an electrophoretic method (Park et al., 2022, below). 25-212-micron pore sizes would allow many smaller microplastics and essentially all nanoplastics to pass through unfiltered. This is a 13 significant limitation, especially given the concerns about these tiny particles in aquatic environments. Systems designed to remove such small particles, like the TENG system, operate on entirely different principles because traditional filtration alone isn’t enough at those scales. Cornell's system would primarily capture larger particles and debris only in runoffs - assuming water run-offs will all go through their filtration system - but would not address the growing problem of microplastic and nanoparticle pollution, which is where the Korean TENG system proves more effective for smaller-sized contaminants (Park, et al, 2022, below). ** Global Market Insights, Inc. PVDF Membrane Market Size - By Material Type (Hydrophilic PVDF Membrane, Hydrophobic PVDF Membrane), By Technology (Microfiltration (MF) PVDF Membrane, Ultrafiltration (UF) PVDF Membrane, Nanofiltration (NF) PVDF Membrane), By End-use & Forecast, 2023 – 2032. Report ID: GM16415. Published August 2023. Accessed January 26, 2025. https://www.gminsights.com/industry-analysis/pvdf-membrane-market. This report highlights the widespread use of polyvinylidene fluoride (PVDF) membranes in filtration systems, particularly in microfiltration and ultrafiltration technologies. PVDF's exceptional durability, chemical resistance, and efficiency in filtering contaminants contribute to its prevalence in water treatment applications. The report estimates the global PVDF membrane market value at $790 million in 2022, projected to exceed $1.6 billion by 2032. However, as a fluoropolymer, PVDF is associated with PFAS (per- and polyfluoroalkyl substances), raising concerns about potential environmental and health impacts despite its utility in filtration systems. **** Park, Byung-Geon, Cheoljae Lee, Young-Jun Kim, Jinhyoung Park, Hyeok Kim, Young Jung, Jong Soo Ko, Sang-Woo Kim, Ju-Hyuck Lee, Hanchul Cho. “Toxic Micro/Nano Particles Removal in Water via Triboelectric Nanogenerator.” Nano Energy, 2022; 100: 107433 DOI: https://doi.org/10.1016/j.nanoen.2022.107433 This study demonstrates a new approach using a triboelectric nanogenerator (TENG) for removing micro- and sub-micron nanoparticles from water smaller than 1µm, leveraging an electrophoretic process driven by the electric field generated by the TENG. Even with the use of advanced materials like the porous-pyramid polydimethylsiloxane (PDMS) layer, the system achieved only a 21.4% removal rate. While this method represents progress in the field of microplastic remediation, it underscores significant limitations in terms of efficiency and cost-effectiveness for large-scale applications. Cornell's mechanical filtration proposals suggest using filters with its huge pore sizes of 25-212 microns, which are considerably larger than those used in the TENG system. Given that this advanced TENG system with smaller pores and electrical enhancement was only able to capture a fraction of microplastic pollutants, serious concerns arise about the efficacy of the filtration methods proposed by Cornell. It is questionable whether such a method will adequately address micro and nano plastic contamination 14 from synthetic turf runoff. Rather than relying on ineffective filtration, it would be far more responsible to critically evaluate and reduce the sources of unnecessary plastic pollution—such as synthetic turf—which contributes significantly to the problem. Cornell’s current plan falls short of effectively mitigating environmental risks, given the evidence of limited success even with more sophisticated technologies. ** Pearce, Graeme. "PVDF Membranes and PFAS: What Impact of the EU’s REACH Legislation?" The MBR Site, May 24, 2023. Updated January 20, 2024. Accessed October 10, 2024. https://www.thembrsite.com/blog/pvdf-membranes-and-pfas-whats-the-difference. This article by Dr. Graeme Pearce explores the growing regulatory challenges surrounding PVDF (Polyvinylidene Fluoride) membranes in the context of the European Union's REACH legislation, which aims to limit or ban the use of PFAS chemicals. Pearce explains the dual role of PVDF in the membrane industry—while PVDF is widely used for water filtration due to its chemical resistance and durability, its classification as a PFAS brings it under scrutiny due to concerns about contamination and environmental impacts. The article offers a detailed comparison between the approaches of the EU and the U.S. in regulating PFAS, with the EU favoring a precautionary approach. **** Silva, Ana L.P., Joana C. Prata, Armando C. Duarte, Amadeu M.V.M. Soares, Damià Barceló, Teresa Rocha-Santos. “Microplastics in Landfill Leachates: The Need for Reconnaissance Studies and Remediation Technologies.” Case Studies in Chemical and Environmental Engineering. June 2021. https://doi.org/10.1016/j.cscee.2020.100072 This study highlights how microplastics and nanoplastics in landfill leachates contribute to the increased leaching of plastic additives, such as plasticizers, and facilitate the adsorption/desorption of hazardous chemicals and pathogens in water. The presence of these plastics raises significant concerns about environmental and human health impacts. Chemicals from plastics, including PFAS, BPA, cadmium, mercury, and lead, are often water-soluble and persistent, making them difficult to remove from water systems with mechanical filtration. As plastics degrade, their surface area increases, accelerating the release of harmful substances. The authors stress the importance of developing remediation technologies to address these threats. *** Simpson, Thomas J., and Robert A. Francis. “Artificial Lawns Exhibit Increased Runoff and Decreased Water Retention Compared to Living Lawns Following Controlled Rainfall Experiments.” Urban Forestry & Urban Greening 63 (2021): 127232. https://doi.org/10.1016/j.ufug.2021.127232. This study examines the hydrological impacts of artificial (synthetic polymer) grass compared to living grass using controlled rainfall experiments. It finds that artificial grass, especially with longer pile heights, produces greater runoff and sheds plastic 15 thatch and fibers, posing environmental concerns; living grass demonstrates superior water retention and drainage control. *** Zhang, Xiaoran, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, and Ziyang Zhang. "Distribution and Health Risk Assessment of Some Trace Elements in Runoff from Different Types of Athletic Fields." International Journal of Environmental Research and Public Health, first published March 2, 2021. https://doi.org/10.1155/2021/5587057. This study evaluates the distribution of seven trace elements (Zinc (Zn), Lead (Pb), Copper (Cu), Manganese (Mn), Cadmium (Cd), Arsenic (As), Chromium (Cr)) in runoff from five types of athletic fields, including artificial turf. The results reveal that artificial turf generates the highest concentrations of these pollutants compared to other surfaces like tennis courts and basketball courts, particularly in initial rainfall events. Notably, pollutants in artificial turf runoff exhibit the least correlation, indicating diverse and unconnected sources such as surface materials, infill, coatings, and external atmospheric deposition. This complexity underscores the unpredictability of synthetic turf's chemical runoff and highlights its heightened pollution risk. Additionally, many of these metals and metalloids are water-soluble and exist in dissolved ionic forms, which cannot be captured by Cornell's proposed mechanical filtration system with a 212-micron pore size. While Cornell claims its infills are “organic” and “PFAS-free,” broader research shows that such toxins can leach from blades, backings, shock pads, adhesives, coatings, and even atmospheric deposition. These findings emphasize the need for comprehensive studies and monitoring. These findings emphasize that pollutants in runoff cannot be attributed to a single source and highlight the need for comprehensive monitoring and mitigation strategies tailored to the unique characteristics of synthetic turf runoff. More Omitted * Zhang, Xiaoran, Yupeng Gu, Yinrui Wang, Junfeng Liu, Yucheng Jiang, Yiran Tian, Ziyang Zhang, Chaohong Tan, Yu Wang, and Haiyan Li. “Occurrence and Risk Assessment of PAHs from Athletic Fields under Typical Rainfall Events.” Water Science & Technology 87, no. 9 (2023): 2159–2171. https://doi.org/10.2166/wst.2023.092. This study examines the release of PAHs from various athletic field surfaces during rainfall, finding significantly higher PAH concentrations in runoff from artificial turf compared to other surfaces. While PAHs are often associated with crumb rubber infill, research has shown that PAHs can also be present in turf blades and backings due to manufacturing additives, plasticizers, recycled plastics and carbon black. This is critical because Cornell’s claim of using plant-based infill for some outdoor turf does not address the contamination risks posed by the synthetic turf itself. From: To: Cc: Subject: Attachments: Sent: Yayoi Koizumi Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org Submission of ZWI's Legal Response and Supplementary Materials EF2024_0816_Zero_Waste_Ithaca_v_Zero_Waste_Ithaca_MEMORANDUM_OF_LAW_I_48.pdf;Revised paragraphs .docx;My notes about Response to Cornell’s _Memorandum_ in Opposition to ZWI Petition on Synturf Projects-1.pdf; 3/18/2025 9:05:45 AM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Members of the Town of Ithaca Planning Board, I am submitting Zero Waste Ithaca’s legal response to Cornell University’s petition regarding the synthetic turf project, along with an additional document—"Revised Paragraphs"—which provides expanded explanations of key arguments from page 14 of 17. This document reflects my own interpretation as a legal layperson attempting to understand Pace Environmental Litigation Clinic (PELC)'s legal argument. In essence, it is my personal translation of the latter half of PELC's argument into more accessible language. Given the strict word limits imposed on our legal filing, it appeared to me PELC had to condense several critical points. As a result, I personally found it necessary to translate and expand the legal document to fully grasp its implications. In doing so, I realized this could also be helpful for members of the Planning Board, as it is essential to ensure that Cornell’s response is not left uncontested or assumed to be the definitive interpretation of the facts. To that end, the attached "Revised Paragraphs" document expands upon page 14 of 17 of PELC's response (EF2024_..., attached) and clarifies several major areas where Cornell’s arguments are misleading, incomplete, or scientifically inaccurate. Specifically, it addresses: The inadequacy of Cornell’s claims regarding microplastic pollution, including their failure to cite legitimate, peer-reviewed research. The improper reliance on mitigation measures instead of conducting a full Environmental Impact Statement (EIS), which is legally impermissible under SEQRA. The omission and misrepresentation of scientific findings on PFAS, microplastics, and volatile organic compounds (VOCs)—all of which pose significant environmental and public health risks. The Planning Board should not accept Cornell’s response as an absolute truth without considering the broader context and evidence. The attached materials demonstrate that a full EIS is legally required to assess the environmental impact of synthetic turf. Additionally, I am attaching my notes regarding Cornell's responses from the administrative records for the court, which include their original submissions to the Town and City of Ithaca Planning Boards. Given the misrepresentation of science in Cornell's submission, I felt compelled to conduct my own research and verify their inaccuracies. It mentions conflicts of interest of Frank Rossi, about whom I have already submitted a public comment. We appreciate the Planning Board’s willingness to carefully review all perspectives to ensure a decision based on a complete and accurate understanding of the environmental risks involved. Please feel free to reach out if further clarification is needed. I hope this further underscores the need for a GEIS for the entire Game Farm Road Project. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are leaning to disregard as you move forward with a Negative Declaration. Sincerely, Yayoi Koizumi Zero Waste Ithaca | BYO - US Reduces Founder | Co-Founder zerowasteithaca.org usreduces.org STATE OF NEW YORK SUPREME COURT: COUNTY OF TOMPKINS ZERO WASTE ITHACA, Petitioner v. ITHACA CITY PLANNING & DEVELOPMENT BOARD AND CORNELL UNIVERSITY Respondents Index No.: EF2024-0816 Justice Mark G. Masler REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF VERIFIED AMENDED PETITION Todd D. Ommen Julianne Frey Attorneys for Plaintiff PACE ENVIRONMENTAL LITIGATION CLINIC, INC. 78 North Broadway White Plains, New York 10603 Phone: (914) 422-4343 Fax: (914) 422- 4433 CI2025-03769 Index # : EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 1 of 17 TABLE OF CONTENTS PRELIMINARY STATEMENT ...........................................................................................1 ARGUMENT .........................................................................................................................2 1. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED THE BECAUSE THE ZWI MEMBERS HAVE STANDING TO BRING THIS LAWSUIT ...............................................................................................................2 A. Petitioner Effectively Alleged Injuries Different from Those of The General Public ................................................................................................2 B. Regardless of Whether or Not the Property is Private, There is Still an Ability to Challenge the Planning Board’s SEQRA Decision .......................5 C. ZWI Has Always Had Standing to Bring This Petition .................................6 2. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK REVIEW” AS REQUIRED BY STATUTE, AND THE NEGATIVE DECLARATION IS ARBITRARY AND CAPRICIOUS. ......................................7 A. The Standard of Review Under SEQRA is A Hard Look Review ................7 1. PFAS ...............................................................................................8 2. Microplastic Shedding ....................................................................10 3. Air Emissions and VOCs ................................................................10 B. The Negative Declaration relies on the Respondent’s Future Actions making it Conditional ....................................................................................11 CONCLUSION ......................................................................................................................12 CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT ....................12 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 2 of 17 ii TABLE OF AUTHORITIES Cases Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849 N.Y.S.2d 112 (3d Dep’t 2007) ................................................................................... 3 Cannon v. Murphy, 600 N.Y.S.2d 965 (2d Dep’t 1993) ................................................................................... 11 Elizabeth Street Garden, Inc v. City of New York, 42 N.Y.3d 992 (2024) ...................................................................................................... 2, 7 Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 613 N.Y.S.2d 257 (2d Dep’t 1994) .................................................................................. 11 Heritage Coal. v. City of Ithaca Planning and Dev. Bd., 644 N.Y.S.2d 374 (3d Dep’t 1996) ................................................................................... 4, 5 Jackson v. New York State Urban Dev. Corp., 67 N.Y.2d 400 (1986) ....................................................................................................... 7 Merton v. McNally, 90 N.Y.2d 742 (1995) ....................................................................................................... 11 New York City Coal. for the Preserv. of Gardens v. Giuliani, 666 N.Y.S.2d 918 (1st Dep’t 1998) .................................................................................. 3 Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768 (Sup. Ct. Westchester Cnty. 2001)...................................................... 6 Saratoga Lake Prot. v. Dep’t of Public Works, 846 N.Y.S.2d 786 (3d Dep’t 2007) ................................................................................... 3 Save Pine Bush, Inc. v. Common Council of City of Albany, 13 N.Y.3d 297 (2009) ....................................................................................................... 1 Save the Pine Bush, Inc. v. Town of Guilderland, 168 N.Y.S.3d 561 (3d Dep’t 2022) ................................................................................... 6 Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715 (3d Dep’t 2002) ................................................................................... 4 Seneca Lake Guardian v. New York State Dep’t Env’t Conserv, 216 N.Y.S.3d 78 (3d Dep’t 2024) ..................................................................................... 6 Shapiro v. Torres, 60 N.Y.S.3d 366 (2d Dep’t 2017) ..................................................................................... 2 W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008) ........................................................................... 9, 11 Rules N.Y. CPLR Rule 1025 (McKinney 2000) .............................................................................. 6 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 3 of 17 iii Regulations 6 NYCRR § 617.7(b) .............................................................................................................. 7 N.Y. Env’t Conserv. Law §8-0101 ......................................................................................... 7 N.Y. Env’t Conserv. Law §8-0109 ......................................................................................... 7 N.Y. Env’t Conserv. Law §27-3313 (2) ................................................................................. 9 CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 4 of 17 1 PRELIMINARY STATEMENT Petitioner Zero Waste Ithaca (“ZWI”) respectfully submits this Reply memorandum in further support of its Amended Petition challenging Respondent Ithaca Planning and Development Board’s (the “Planning Board”) arbitrary and capricious finding under the State Environmental Quality Review Act (“SEQRA”) that Respondent Cornell University’s (collectively with the Planning Board, “Respondents”) use of artificial turf fields will have no possible significant adverse environmental impact (the “Negative Declaration”). The Planning Board’s failure to order an Environmental Impact Statement (“EIS”) violates SEQRA’s fundamental purpose: investigating and mitigating environmental harm before it occurs. ZWI brings this petition because its members—who regularly work, study, and engage on Cornell's campus and community—will be directly harmed by the disregard for public health and environmental responsibility. Rather than focusing on defending the Negative Declaration on the merits, Respondents initially allege that ZWI has no standing to bring this suit. Respondents first argue that ZWI’s members suffer no particularized harm from the Negative Declaration, but this contention ignores that, unlike the public at large, ZWI’s members rwork, study, and engage with Cornell’s campus every day. ZWI has demonstrated that its members would suffer harm different from that of the general public including the degradation and recreational, environmental and aesthetic interests in nature and green space. Save Pine Bush, Inc. v. Common Council of City of Albany, 13 N.Y.3d 297, 304 (2009). Moreover, ZWI had the ability to bring suit as an unincorporated association, but even if this were a defect, that defect has now been rendered moot by ZWI’s incorporation. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 5 of 17 2 Similarly, Respondents’ assertion of a proper “hard look” review of the potential environmental impacts and the finding of no significant adverse environmental impacts largely ignores the extensive record in this matter. The fact that Respondents can point to a handful of papers or studies that at least in part support their position does not establish that there will be no possibility of any adverse environmental impact, as required by SEQRA. Elizabeth Street Garden, Inc v. City of New York, 42 N.Y.3d 992, 995 (2024). Absent such a showing, where, as here, there is ample research and analysis showing potential impacts, the only legal path was for Respodents to complete an EIS. Citing only a handful of studies—while disregarding a substantial body of research demonstrating potential harm—does not satisfy SEQRA’s “hard look” requirement. ARGUMENT I. THE COURT SHOULD ALLOW THE VERIFIED PETITION TO PROCEED BECAUSE THE ZWI MEMBERS CAN ESTABLISH STANDING TO BRING THIS LAWSUIT. Respondents assert that Petitioner lacks standing because its members do not suffer an injury different from the general public, that the members cannot access the project site, and ZWI’s unincorporated status at the time the Petition was filed. Each of these contentions fails after review of the record and circumstances of this dispute, as well as developments since the filing of the Petition. A. Petitioner Sufficiently Established Injuries Different from Those of the General Public. To establish standing under SEQRA, a petitioner must demonstrate an environmental injury different from the general public and that the alleged injury falls within the scope of interests being protected by SEQRA. Shapiro v. Torres, 60 N.Y.S.3d 366, 368 (2d Dep’t 2017). CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 6 of 17 3 The offices of ZWI member Emily Jernigan, a Cornell University full-time staff member and Amina Mohamed, a Ph.D. candidate in Ecology and Evolutionary Biology, are located very near the proposed project site. Respondent asserts that their offices, 560 feet and 265 feet away from the project site, respectively, are too far away from the site to establish standing. (NYSCEF Doc. No. 43, pp 11.). Referencing New York City Coal. for the Preserv. of Gardens v. Giuliani, Respondents compare these facts, two community members of a private institution as similar to trespassers who had established a community garden on a vacant lot. 666 N.Y.S.2d 918, 918-19 (1st Dep’t 1998) aff’g 670 N.Y.S.2d 657, 659 (Court dismissed a SEQRA petition on standing grounds as petitioners did not have any legal right to the garden). Ms. Jernigan and Mohamed did not use the field as it is restricted to athletics, and ZWI does not contend that the project site is available to them. But, notwithstanding that the field may be off limits to non-athletes, proximity can still establish standing. As Cornell community members, ZWI members must be in the vicinity for work and study and have an interest in and enjoy the natural environment. That environmental is what is threated by the PFAS, microplastics and other toxins that would be released by the proposed field, as set forth in the Amended Petition. Indeed, proximity established by ZWI’s affiants is well within the range of that found sufficient for SEQRA standing. The Third Department has previously held that proximity within 1,000 feet of a development site can be sufficient to establish. See, Saratoga Lake Prot. v. Dep’t of Public Works, 846 N.Y.S.2d 786, 791 (3d Dep’t 2007) (petitioners demonstrated standing from 1,000 feet of development); Basha Kill Area Ass’n v. Planning Bd. Of Town of Mamakating, 849 N.Y.S.2d 112, 115 (3d Dep’t 2007) (petitioner alleged an injury differentiated from that of the general public because her residence was 941 feet away from the proposed project and identified an environmental concern arising from that proximity). Ms. Jernigan and Mohamed’s offices are CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 7 of 17 4 located much closer, within 560 and 265 feet of the project site, well within a distance sufficient for standing (NYSCEF Doc. No. 43, memorandum of law in support denying petition at 11). Respondents further argue that even if their offices were not too far removed, the campus has ample green spaces for the Petitioners to enjoy and interact with nature. (NYSCEF Doc. No. 43 at 16-17). But this argument entirely misses the point of SEQRA, which is to protect the site at issue. Ms. Mohamed said she often takes breaks in the area of the field. (NYSCEF Doc. No. 11, affirmation of Amina Mohamed at 2). The existence of other green spaces is simply irrelevant. First, those neighboring green spaces are exactly what would be impacted by the toxins emanating from the field, as multiple studies submitted to Respondents demonstrate. In any event, SEQRA does not permit the degradation of one green space simply because other green spaces may exist nearby. Ms. Mohamed does not allege to take breaks elsewhere; she takes breaks around the project site. (Id.) The area she frequents, close to her office, the subject of this petition – not other green spaces. Respondents correctly state that proximity alone is not always enough to confer standing. Save Our Main St. Bldgs. v. Greene County Legis., 740 N.Y.S.2d 715, 717-18 (3d Dep’t 2002). However, the matter here is substantially different from Save Our Main St. Bldgs., where the petitioners did not allege any unique environmental injuries. Save Our Main St. Bldgs., 293 A.D.2d at 909 (petitioners alleged increased traffic concerns, one concerned about more traffic for their store on the main street, noise complaints, an aesthetic injury despite the project not being visible as it was on the same side of the street as petitioner’s store, and a petitioner who was concerned about educational walks through a public main street.) Respondents’ reliance on Heritage Coal. v. City of Ithaca Planning and Dev. Bd., to demonstrate as another example of how the appreciation of a building, Cornell’s Sage Hall, was not enough of an injury, is CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 8 of 17 5 misplaced. 644 N.Y.S.2d 374, 376-377 (3d Dep’t 1996) (dismissal of a SEQRA petition based on standing; three educators failed to show how their injury was different from that of the general public.) Heritage Coal. is distinguishable from the present matter because of the goals of SEQRA; “...the diminution of [their] appreciation of Sage Hall and [their] use of it as a teaching tool, is not, without more, within the zone of interest sought to be promoted or protected by either SEQRA…” Id. at 376. In contrast, there can be no question that the environmental injuries alleged here – environmental contamination from PFAS, micro plastics and other toxins – are within the zone of interests of SEQRA. ZWI members demonstrate unique environmental harms congruent with the SEQRA’s aims and further allege a much closer connection to Cornell’s campus than the public at large. See, N.Y. Envtl. Conserv. Law §8-101. Ms. Jernigan and Mohamed, by virtue of their proximity, interests in the natural state of the campus, members of the faculty and staff, and Ms. Mohamed’s breaks in the areas, establish harm greater than that of the general public. B. Regardless of Whether the Property is Private, Petitioner Can Still Challenge The Planning Board’s SEQRA Decision. Respondents’ next argument focuses on the project site functioning as an athletics field that is only accessible to authorized students; therefore, Respondents argue, ZWI members could not have standing for a field they cannot enter the field. NYSCEF Doc. No. 43, 16-17. Case law does not indicate that Petitioners must have access to the site to sustain an injury from a site’s development. It is not and cannot be the law that development on a privately owned site is immune from SEQRA challenges. Indeed, as discussed below, development will often naturally occur on private property, and courts have found proper standing for environmental groups nevertheless. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 9 of 17 6 The Petitioner’s standing should be considered within the entire scope of the facts. The fact that the field may be, in a sense, “private” does not mean that those in proximity cannot have standing. If it were otherwise, nobody would ever have standing to challenge development on private property, which would eviscerate the purpose of SEQRA. To the contrary, the mere fact that a standing witness does not have legal access to a property does not defeat standing. Indeed, recently the Third Department held just that. In Save the Pine Bush, Inc. v. Town of Guilderland, 168 N.Y.S.3d 561, 566 (3d Dep’t 2022), the court held that an environmental group had standing to challenge a development on private property due to the group’s interests in the surrounding environment. See also, Seneca Lake Guardian v. New York State Dep’t of Env’t Conserv., 216 N.Y.S.3d 78, 81 (3d Dep’t 2014) (where the dumping of leachate into a water body not owned by the plaintiff, found successful standing). C. ZWI Has Always Had the Legal Ability to Bring This Petition, and Now Has Been Incorporated. Finally, Respondents’ argument that ZWI lack the capacity to sue was incorrect and, in any event, is now moot, as ZWI is no longer an unincorporated entity. New York does allow unincorporated organizations to bring legal actions, pursuant to the CPLR § 1025, which provides that “[an action] may be brought by or against the president or treasurer of an unincorporated association on behalf of the association in accordance with the provisions of the general associations law.” While Ms. Koizumi, the founder of ZWI, may not be explicitly listed as the organization's “president,” she functions and operates as such, performing the “equivalent functions and responsibilities” of a small grassroots organization by advocating for change and informing the public of potential risks. Pelham Council of Governing Bds. v. City of Mount Vernon Indus. Dev. Agency, 720 N.Y.S.2d 768, 770 (Sup. Ct. Westchester Cnty. 2001) (provides that an unincorporated organization may proceed in a lawsuit if they function like a treasurer or CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 10 of 17 7 president of an organization); see, NYSCEF Doc. No. 18 at pp 5 (demonstrating Ms. Koizumi’s advocacy.) Additionally, the Respondent’s arguments about undertakings are entirely irrelevant, as there has not been a preliminary injunction at this point and the issue of an undertaking is not before the Court. NYSCEF Doc. No. 43 at 20. In all events, the argument is now moot. As of January 27, 2025, ZWI is recognized by New York State as a not-for-profit corporation. (See Affirmation of Yayoi Kozumi, submitted herewith.) II. THE COURT SHOULD DENY THE MOTION TO DISMISS BECAUSE THE PLANNING BOARD FAILED TO TAKE THE REQUIRED “HARD LOOK” AS REQUIRED BY STATUTE. A. The Standard of Review Under SEQRA is A Hard Look Review. ZWI will suffer tangible environmental harms from the planning board’s negative declaration that the project will not have any potential adverse environmental impacts. (6 NYCRR § 617.7(b) (emphasis added)). SEQRA aims to “...encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate environmental damage and enhance human and community resources…” N.Y. Envtl. Conserv. Law § 8-0101. To accomplish these goals, applicants must complete an environmental assessment form (EAF) to determine when a longer, more in-depth environmental assessment, an EIS, is necessary. Id. at § 8-0109. The determination of whether to complete an EIS must be based on the agency (here the Planning Board) taking a “hard look” at all potential impacts. A “hard look” review is when “the lead agency [identifies] the relevant areas of environmental concern, [takes] a ‘hard look’ and [makes] a reasoned elaboration’ on the basis for its decision.” Elizabeth Street Garden, 42 N.Y.3d at 994 (2024) (omitting internal quotations); see, Jackson v. New York State Urban Dev. Corp., 67 N.Y.2d 400, 417 (1986.) If, after taking that “hard look,” there are any potential adverse impacts, an EIS is the only permissible next step under SEQRA. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 11 of 17 8 Put another way, where the material before the reviewing agency indicates that there is any potential for a significant impact, the agency cannot rationally determine that the project will not have a significant adverse impact on the environment. Elizabeth Street Garden, 42 N.Y.3d at 994. Respondents assert that the “multiple hours” spent at planning board meetings, reviewing documents, and asking some questions was enough to counter the numerous contradicting information and studies and glaring biases from fact gatherers the planning board relied on. (NYSCEF Doc. No. 43 at 24-25, 21). But the amount of time is not the question here; rather, the question for this Court is whether that record revealed any potential impacts. The quantity of time spent on an issue is not an indication that the Planning Board had a substantive review of possible adverse environmental impacts. The mere fact there were 70 pages of citations to contradictory studies presented to the Planning Board should have triggered an EIS as it indicates – at a minimum – an open question as to environmental impacts. NYSCEF Doc. No. 18 at pp 5 (One organization’s, ZWI’s, submissions to the Planning Board for consideration.) 1. PFAS Respondents have asserted time and time again that the science proving that artificial turf fields is sound, going so far as saying that “[o]ver 100 scientific, peer reviewed, published studies have been performed worldwide evaluating the potential health risks with turf fields that use crumb rubber. We are not aware of any peer reviewed scientific studies that draw an association between adverse health effects and use of crumb rubber.” NYSCEF Dos. No. 43 at 4. It is again repeated that the PFAS concerns are not serious. Id. at 20 (Respondent states that they have “rebutted” the claims). The question of health impacts is certainly relevant, but an EIS is triggered under SEQRA by any significant adverse environmental impact, not just human health CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 12 of 17 9 impacts. Petitioner was not required to prove medical causation to trigger an EIS. Potential environmental impacts were obvious from the submissions to the Planning Board. The bibliography provided to the Planning Board has several relevant studies affirming synthetic turf is a concern. See generally, Bibliography NYSCEF Doc. No. 20. Similarly, though the Respondents have stated that over 100 scientific and peer reviewed studies claim that there are not adverse health effects linked to the use of crumb rubber, Respondents only cite to six. R. 0641-42. While Respondent’s insist that their own submitted documentation proved more compelling to the Planning Board, that PFAS would not be a significant concern, Respondent’s seemed to contradict their statement earlier in their memo that PFAS contamination is pervasive already. NYSCEF Doc. No. 43 at 20, 4 (respondents allege their own material is persuasive enough to the planning board that PFAS concerns are unimportant but suggest in their statement of the facts their summary suggests that because PFAS are already pervasive in the environment the amount from synthetic turf won’t be significant). Arguing that contamination is already present should not and does not establish no possible environmental impacts. Respondents also assert that because they modified their project to comply with a new New York state ban on carpet containing PFAS, including synthetic turf, going into effect in 2026, the Planning Board was entitled to defer to Cornell’s compliance with applicable law when issuing a negative declaration. N.Y. Env’t Conserv. Law §27-3313 (2). However, the ban going into effect is further evidence that the Planning Board’s negative declaration decision was arbitrary and capricious; environmental risks are associated, which is why there is a ban going into effect in the near future. Id. There is a recognized environmental threat substantial enough to warrant a statewide ban, this should not be ignored under SEQRA. Likewise, the case law Respondents rely on to ameliorate concerns hinges on having already completed a CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 13 of 17 10 comprehensive EIS. W. Beekmantown Neigh. Ass’n Inc. v. Zoning Bd. of Appeals of Town of Beekmantown, 861 N.Y.S.2d 864, 866 (3d Dep’t 2008). This is all Petitioner here seeks: completion of an EIS to examine these open issues. 2. Microplastic Shedding Respondents assert that they have “submitted extensive documentation from scientific studies” about microplastics. NYSCEF Doc. No. 43. at p. 21. However, this is misleading as the record indicates that one letter, from the Respondent’s employee Dr. Frank Rossi, addressed microplastics. R. 0622-23. The content of Dr. Rossi’s letter focused primarily on the necessity of a synthetic turf field and the alleged adequacy of a microplastic filter. Id. The letter only referenced one scientific study, and it did not name it. Id. This one reference without citing a relevant study is in stark contrast from the alleged extensive documentation. ZWI submitted several studies from credible environmental journals and other sources explaining the risks of microplastics entering the environment. NYSCEF Doc. No. 20 at 33. ZWI submitted information from at least two scientific studies, Chand et al., 2024 and Park et al., 2022, demonstrating that the proposed stormwater filter, added to mitigate plastic pollution in runoff, would not be sufficient as the plastic degrades and becomes smaller than the 212-micron pore size of the filter, leading to plastic pollution and contamination in waterways. R. 1425. In this same vein, the EPA in 2024 documented that the majority of people who had used synthetic turf fields would have find the fill on their person, in their cars and in their homes after the fact (R.1700) demonstrating the difficulty and confirming that synthetic turf users routinely carry microplastics on their skin, shoes, and clothing, dispersing them into homes, cars, and water systems. CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 14 of 17 11 3. Air Emissions and VOCs Despite the Respondent’s contentions, the record lacks scientific studies showing a consensus that emissions and VOCs from synthetic turf fields have no health impacts. Initially, as noted above, Petitioner was not required to show health impacts – rather, environmental impacts are the question. In any event, Respondents cite to a 2018 Guidance Document from the New York State Department of Health quoting that the exposures to VOCs, SVOCs and airborne particulate matter was insignificant and not unlike the exposure a person would have on a natural turf field. NYSCEF Doc. No. 43 at 21-22. Respondents failed to include the part of the quote that says when the synthetic field is not exposed to open air, when “collected from an indoor synthetic turf field [air samples] had higher concentrations [of VOCs, SVOCs and airborne particulate matter] than the outside fields.” R. 3152. The earlier 2018 study in complete context corroborates the recent findings from a 2023, among many others, that microplastic inhalation is a confined indoor space is an elevated risk due to microplastic’s small size and density compounded with their ability to stay in the space due to a lack of air circulation. R.1426. ZWI raised several other concerns about air borne microplastics and environmentally persistent free radicals from reputable academic sources, the Center for International Environmental Law and Huang et al., 2022, that went unaddressed. Id. B. The Negative Declaration relies on the Respondent’s Future Actions making it Conditional The insufficient detail provided in the negative declaration reasoning, despite the variety of potential environmental impacts, means the Planning Board's issuance of the negative declaration violated SEQRA. See, Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 613 N.Y.S.2d 257, 259 (2d Dept 1994); Cannon v. Murphy, 600 N.Y.S.2d 965, 968 (2d Dept 1993). CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 15 of 17 12 The Planning Board's reliance on future actions and mitigation measures as justification for foregoing an EIS is impermissible. The cases the Respondents point to, W. Beekmantown Neigh. Ass’n Inc and Merton v. McNally, are fundamentally different in the extent of their mitigation. W. Beekmantown Neigh. Ass’n Inc, 861 N.Y.S.2d at 866 (mitigation after an EIS had already been done did not require another EIS); Merton v. McNally, 90 N.Y.2d 742, 755 (1995) (mitigation entailed adding an additional 2 feet of buffer space). Ultimately the planning board’s decision was not merely arbitrary and capricious given the record but also patently wrong about the facts. It is established that it is not for this Court to determine the whether the planning board’s reasoning for a negative declaration is adequate, it is within the scope to determine if it complied with SEQRA requirements in finding no potential significant impact. Here, due to its failure to adequately assess key issues in the record, the Planning Board plainly did not comply. CONCLUSION For the reasons outlined above, Petitioners respectfully request that this court maintain allow our petition to go forward. Dated: February 13, 2025 White Plains, NY Respectfully submitted, _________________________ Todd D. Ommen Pace Environmental Litigation Clinic, Inc. 78 North Broadway White Plains, NY 10603 (914) 422-4343 tommen@law.pace.edu CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 16 of 17 13 CERTIFICATE OF COMPLIANCE REGARDING WORD COUNT LIMIT The undersigned attorney hereby certifies: This document complies with the word count limitations pursuant to Rule 202.8-b (c) of the Uniform Civil Rules for the Supreme Court and the County Court as amended by the Administrative Order 270-20, effective February 1, 2021. According to the word processing system used in this office, this document, exclusive of the sections excluded by Rule 202.8-b (b), contains 3,595 words. Dated: February 13, 2025 _____________________________ Todd D. Ommen CI2025-03769 Index #: EF2024-0816 FILED: TOMPKINS COUNTY CLERK 02/13/2025 08:37 PM INDEX NO. EF2024-0816 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 02/13/2025 17 of 17 Summary of Objections to Cornell’s 30-Page Legal Memorandum 1. Misrepresentation of Scientific Evidence and Cherry-Picked Studies ● Cornell claims that “over 100 peer-reviewed studies” support synthetic turf safety (page 4) but fails to list them. ● Instead, their April 2024 submission “Additional Materials” contains only 12 references (R1571-R1572), three of which have clear industry conflicts of interest: ○ Peterson et al. – Connected to the recycled rubber industry. ○ Schneider et al. (2020) – Funded by synthetic turf and tire recycling companies. ○ Blair – Advised by Laura Green, a discredited industry consultant known for downplaying PFAS risks. ● Two of the 12 references come from consulting firms (Tetra Tech and TRC), which reference each other’s reports—creating an industry echo chamber. This was brought up repeatedly in public comments. Notably, Tetra Tech’s report was rejected by the Town of Oak Bluffs on Martha’s Vineyard in MA. The town proceeded to ban artificial turf despite Tetra Tech’s report. This fact presented in multiple public comments multiple times is conveniently omitted from Cornell’s presentation. ● Of the three EPA sources cited in the 12 references on which Cornell’s legal response rests on, only one—the 2019 report, Tire Crumb Rubber Characterization—is directly related to synthetic turf issues involving tire-derived crumb rubber (TDCR). This report, commonly referred to as FRAP 1 (Federal Research Action Plan, Part 1 - Final Report Part 1, Tire Crumb Rubber Characterization), has been widely mischaracterized by the synthetic turf industry. In their response (R1564-1567), Cornell relies on FRAP 1 to justify synthetic turf installations, yet their interpretation is misleading. The EPA explicitly stated that FRAP 1 was not a risk assessment and that the study was only intended to characterize the presence of chemicals in tire crumb rubber, not determine the risks of exposure or health effects. However, Cornell presents the findings as though they confirm the safety of synthetic turf, when in reality, the report did not make any determinations about health risks. This deliberate misrepresentation mirrors a pattern of selective and misleading use of evidence throughout their response. The FRAP1 also confirms that recycled tire crumb rubber contains metals, PAHs, phthalates, and other chemicals. Some of these are known to be carcinogenic or have other toxic effects. The report also shows that volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) are emitted, particularly at higher temperatures (60°C/140°F)—a temperature synthetic turf commonly reaches in summer. By downplaying these emissions or ignoring temperature-dependent off-gassing, they are omitting critical data that affects health risk. FRAP 1 does not quantify real-world human exposure, meaning Cornell cannot legitimately conclude that synthetic turf poses "no risk" based on this study alone. Cornell also fails to address bioaccessibility and exposure uncertainties addressed in FRAP1. The EPA measured how metals and chemicals leach into simulated gastric fluid, saliva, and sweat, finding that some metals are bioaccessible. FRAP 1 also acknowledges significant data gaps in its report, particularly regarding long-term exposure, biomonitoring, and cumulative effects. Cornell cherry-picks evidence while ignoring the study’s stated limitations by presenting FRAP1 as definitive proof of safety. In addition to FRAP 1, Cornell lists two other EPA sources that have little or no direct relevance to synthetic turf or TDCR. The first, “Regional Screening Levels for Chemical Contaminants at Superfund Sites - Generic Tables”, is an EPA database of chemical exposure guidelines used primarily for hazardous waste sites under the Superfund program. This document is completely unrelated to synthetic turf and has no relevance to tire crumb rubber exposure scenarios on athletic fields. This report is referenced on R1564. The document states that when New York State Soil Cleanup Objectives (SCOs) were unavailable, they defaulted to the EPA Regional Screening Levels (RSLs) as a substitute. However, the EPA’s RSLs are not direct regulatory limits—they are risk-based screening tools used to determine if further evaluation is needed. This is not equivalent to New York’s SCOs, which are legally enforceable cleanup standards. The EPA RSL page they reference (linked here) explicitly states that RSLs do not determine cleanup levels; they are preliminary screening values intended to flag potential areas of concern. Cornell's conclusion that synthetic turf is "safe" based on EPA RSLs is not scientifically valid. Instead of providing a site-specific risk assessment using New York’s actual regulatory cleanup standards, they are misapplying an EPA tool meant for screening, not final safety determinations. This creates a false impression of safety and ignores the precautionary principle that should be applied when dealing with long-term contamination risks. The second source, “Learn About Heat Islands”, is a general EPA webpage discussing urban heat islands, including buildings, pavement, and land use, but not synthetic turf specifically. While synthetic turf contributes significantly to urban heat island effects, this source does not analyze synthetic turf's heat retention properties in any meaningful way. This EPA source is referenced on R1570 where Cornell claims the EPA states heat islands “build throughout the day and become more pronounced at night.” Ths misrepresents the source. The EPA page does acknowledge that urban materials release stored heat after sunset, contributing to higher nighttime temperatures relative to rural areas, but it does not state that nighttime temperatures exceed daytime temperatures or that heat islands intensify at night. This is a misleading paraphrase that overstates the EPA’s wording to fit Cornell’s narrative. Its inclusion suggests an attempt to appear comprehensive while failing to cite any substantive research on the specific heat hazards of artificial turf fields. Most notably, despite relying so heavily on FRAP 1, Cornell completely ignored FRAP 2 (2024) in its April 2024 submission, even though FRAP 2 was published that same month. The second July submission does mention FRAP 2 but only to misrepresent its findings. On page 4 of their July 2024 submission of Additional Materials (R0634), Cornell falsely claims that a “study published in 2024 by USEPA that used biomonitoring of athletes demonstrated that no exposures occurred to the chemicals in synthetic turf and crumb rubber.” This statement is demonstrably false. FRAP 2 explicitly found that players are exposed to hazardous chemicals through inhalation, dermal contact, and ingestion, particularly in indoor settings where concentrations were highest. By ignoring FRAP 2 entirely in their April submission and then distorting its findings in their July submission, Cornell has engaged in a clear attempt to downplay exposure risks while selectively citing irrelevant EPA sources. This pattern of misrepresentation is further evident in how Cornell frames the issue of exposure. Throughout their response, they repeatedly claim that while chemicals are present in synthetic turf, the risk of exposure is negligible and not a concern. This is a deliberate mischaracterization of the scientific process and regulatory approach to chemical exposure. The presence of hazardous substances alone is not what determines risk—the question is whether and how people are exposed, and whether cumulative, chronic exposure poses long-term health effects. FRAP 2 was specifically designed to answer these questions, yet Cornell systematically avoids engaging with its findings because doing so would undermine their central argument. In their April submission, Cornell spends four full pages misrepresenting FRAP 1 (R1564-1567), treating it as though it supports their claim that synthetic turf is safe, when in reality, FRAP 1 did not assess risk at all. The EPA 2019 report explicitly states that it is not a risk assessment. Instead, it is a characterization study that identifies the chemical composition of tire crumb rubber but does not evaluate the health risks associated with exposure. Then, in their July submission, they strategically acknowledge FRAP 2 only to distort its conclusions (R0634), rather than engaging with the actual findings of increased exposure risks. This demonstrates an intentional and calculated effort to manipulate the scientific record to serve a predetermined conclusion in favor of synthetic turf. If Cornell were genuinely committed to scientific integrity, they would have prominently addressed FRAP 2’s findings in full, rather than omitting it in April and distorting it in July. By selectively citing an outdated EPA report while ignoring and later misrepresenting the agency’s most recent and relevant research, Cornell’s response lacks credibility. Their use of unrelated EPA sources further underscores an effort to obscure rather than clarify the scientific and regulatory understanding of synthetic turf risks. This is not a rigorous or honest engagement with the evidence—it is a strategic misrepresentation designed to manufacture doubt and avoid accountability for the well-documented exposure risks posed by synthetic turf. ● Of the 12 references on R1571-1572, Cornell also misrepresents Pavilonis et al. study on R1564. While Pavilonis et al. (2014) found that most metals and SVOCs had low bioaccessibility, they explicitly stated that lead was an exception, with some fields containing high levels. Their risk assessment showed that children could have elevated blood lead levels depending on exposure, which contradicts Cornell’s blanket claim of safety. The authors recommended that turf should be screened for lead before installation, which implies a concern that Cornell completely ignores. Further, the study analyzed only seven fields—hardly a representative sample of all artificial turf. The study used EPA’s risk assessment methods, but as we've seen with their misuse of EPA RSLs, regulatory thresholds are not always health-protective—especially for chronic, low-dose exposures. The Pavilonis study itself acknowledges data gaps, but Cornell’s summary presents it as definitive proof of safety, which is scientifically dishonest. ● Cornell also misrepresents the findings of CY Jim’s study on the heat island effect listed as one of the 12 references on R1570. A recent public comment addresses that. Please see the tab CY Jim for details. This leaves only Pronk et al (2020) out of 12 as a valid study - even that study is also misrepresented, as it also acknowledges data gaps and explicitly state that more research is needed on long-term exposure, particularly for inhalation and dermal absorption of chemicals released from crumb rubber, and that athletes and children have higher exposure due to direct skin contact and inhalation of volatile compounds, which could pose risks not fully captured by existing guidelines. It also notes that athletes and children have higher exposure due to direct skin contact and inhalation of volatile compounds, which could pose risks not fully captured by existing guidelines. In conclusion, Cornell cherry picked the entire 12 studies. Compare this to Zero Waste Ithaca’s bibliography containing several dozens of valid, reputable, independent peer-reviewed studies, legitimate reports, and testimonies from independent experts. ● Cornell’s July 2024 submission of “Additional Materials” cherry-picks from our originally submitted 70-page bibliography and misrepresents studies for their purposes —public comments for the newly proposed field address this. ○ On R0637-R0638, Cornell’s reliance on Magnusson & Macsik (2017) to justify synthetic turf’s emissions and human health safety is misleading and incomplete. They cherry-pick this study while ignoring multiple studies we submitted on synthetic turf emissions, including research on methane emissions from degrading turf by Dr. Sarah Jean-Royer (2018). Cornell’s emissions comparison ignores these critical factors and utterly fails to acknowledge that natural grass fields sequester carbon, whereas synthetic turf continuously emits greenhouse gases. Synthetic turf’s emissions must also be evaluated across its entire lifecycle, including raw material extraction, manufacturing, transportation, installation, use, and disposal. Cornell also misrepresents the study’s findings on human health risks, claiming that the introduction includes a table summarizing 26 studies, all demonstrating minimal risk. This is false. While the study contains a table listing various studies, it does not conclude that all 26 studies find minimal risk. Instead, the table categorizes different environmental and health considerations, and some of these studies acknowledge concerns about chemical exposure, microplastic release, and environmental degradation. Magnusson & Macsik (2017) primarily focus on energy use and emissions, not toxicology or microplastic pollution, making it an inappropriate reference for health risk assessments. Cornell distorts the intent of this table by falsely presenting it as definitive proof of synthetic turf safety. A scientifically sound approach would require a comprehensive review of emissions, microplastic pollution, PFAS contamination, and lifecycle environmental costs, rather than relying on a single, cherry-picked study. ○ On R0638, Cornell’s response misrepresents the findings of Tarafdar et al. (2019). Cornell’s response to Tarafdar et al. (2019) is a textbook example of selective interpretation designed to downplay the risks of synthetic rubber surfaces. Their claim that PAHs detected in the study originate primarily from external sources like vehicular emissions and fossil fuel combustion does not negate the fact that poured-in-place (PIP) rubberized playgrounds were found to pose a 10-times higher cancer risk than uncovered soil playgrounds. Cornell conveniently omits a critical point: the rubberized surfaces themselves act as accumulators of PAHs, trapping these toxic compounds and increasing children’s exposure risk. Even if the study did not explicitly identify tire-derived crumb rubber (TDCR) as the main PAH source, that does not mean TDCR is free from PAHs. In reality, TDCR has been well-documented to contain and release PAHs as it breaks down—a fact confirmed by experts, even by the 2019 EPA report they reference to. By narrowly focusing on settled dust, Cornell ignores the larger body of evidence showing that PAHs are intrinsic to synthetic rubber materials. Instead of addressing the clear finding that children face significantly higher PAH exposure in rubberized playgrounds, they attempt to shift blame to external pollution, sidestepping the critical health implications of these toxic surfaces. It is also curious why Cornell focuses on this particular study on TDCR which is not ○ On R0638-0639, Cornell’s response downplays the Huang et al.’s (2023) findings by suggesting that U.S. tires are different from Chinese tires—a baseless claim with no supporting evidence. Tires worldwide contain similar toxic compounds, and if Cornell truly believed there was a difference, they should present evidence. They also claim that EPFRs (environmentally persistent free radicals) are "not typically used as a measure of health effects," which is misleading. EPFRs are widely studied in air pollution research because they produce reactive oxygen species (ROS), which drive oxidative stress, inflammation, and cellular damage—a key mechanism in many diseases, including cancer and respiratory conditions. EPFRs are an established risk factor in toxicology. While Cornell acknowledges that crumb rubber particles are airborne, increase EPFRs in saliva, and inhibit enzyme function, they try to neutralize the findings by saying these effects weren’t statistically significant at measured levels—ignoring cumulative exposure, long-term impacts, and individual variability. ○ On R0639, Cornell’s dismissal of Peaslee’s findings by focusing on a four-slide presentation rather than engaging with the broader body of research on PFAS in artificial turf is a clear case of cherry-picking. While they attempt to discredit his calculations by questioning sample preparation and methodology, they conveniently ignore peer-reviewed studies that provide extensive evidence of PFAS contamination in synthetic turf, including Peaslee and Mello (2022), Massey et al. (2020), Lauria et al. (2022), Murphy (2022), Negev et al. (2022), and Siegel (2024) and more, all available in our bibliography. Moreover, Dr. Peaslee supervised Whitehead’s 2023 PhD dissertation, which systematically analyzed 27 turf blade samples and confirmed the presence of PFAS in all of them, including fluorinated polymer processing aids, yet Cornell makes no mention of these rigorous research. Their selective engagement with a single presentation, rather than the full range of published studies demonstrating the dangers of PFAS in turf, exposes their attempt to downplay the issue rather than engage in an honest scientific discussion. ○ On R0639, Cornell also outrightly seems to tell untruth when they discuss Gould 2022 study that survey’s past literature on the injuries from playing on synthetic turf surfaces. Cornell says, “This article has been responded to previously within these materials.” However I find no reference anywhere in the document other than this. Cornell provides no meaningful engagement with Gould et al.’s findings on higher lower-extremity injury rates on synthetic turf. ○ On R0640, Cornell’s reading of the study by De Haan et al. (2023) attempts to downplay the relevance of the findings to their proposed artificial turf field by emphasizing differences in construction and drainage systems between European and U.S. turf fields. While U.S. fields often include sand layers, there is no evidence that this significantly prevents the release of microplastics into stormwater (See the list of videos showing turf deterioration in the US in the separate tab), nor does it address fiber loss through wear, wind dispersion, and maintenance activities. The study found that artificial turf fibers make up over 15% of mesoplastics and macroplastics in aquatic environments, with significant quantities detected in both river and ocean waters. This confirms that artificial turf is a major contributor to plastic microplastic pollution, regardless of regional construction differences. Bethesda, MD. 2019. Cornell’s dismissal of the University of California, Santa Barbara decision to opt for natural grass based in a large part due to this study as being solely due to proximity to the ocean ignores the broader implications of the study: artificial turf fibers are a persistent pollutant that enter ecosystems through multiple pathways, including air, soil, and indirect water transport. Given that Cornell’s campus is near Cayuga Lake and its tributaries, the potential for fiber migration into drinking water supplies is undeniable. ○ On R0640, Cornell focuses on the recommendation to incorporate additional trees, shrubs, and natural grasses when using artificial grass by Sanchez-Sotomayor et al. (2022). While the study does suggest that natural elements can benefit biodiversity, this is a minor point in the broader discussion. The study primarily emphasizes the negative impact of artificial grass on bird diversity at every level (alpha, beta, gamma) and the need to reconsider its use in urban parks. Cornell's summary downplays the study's main conclusion, which is that artificial grass significantly reduces bird diversity. Additionally, the study surveyed 45 parks in eastern Spain, conducting detailed biodiversity analyses, including statistical modeling. Cornell oversimplifies this by stating parks were surveyed "once for a period of two hours in the mornings," which makes it sound like a casual observation rather than a rigorous scientific study. ○ On R0640-0641, Cornell’s response to the portion of Zero Waste Ithaca’s bibliography concerning the failure of plastic recycling constructs a strawman argument by misframing the issue. Rather than addressing the documented failure and environmental and public health harms associated with recycling of plastic turf—such as microplastic pollution, toxic chemical contamination, air pollution —they attempt to minimize the problem by comparing synthetic turf waste to the total volume of plastic waste in the U.S. This comparison is irrelevant and misleading, as synthetic turf pollution is not merely a matter of weight but of persistent contamination, localized environmental damage, and the absence of viable disposal solutions. Furthermore, Cornell provides no credible citations for their disposal estimates, relying instead on figures that appear to originate from the synthetic turf industry itself. Their claim that only 6,500 tons of synthetic turf are disposed of annually is implausibly low, contradicting both industry and independent research on turf field disposal. For detailed account of the numbers, see the separate tab named “Recycling.” ○ On R0641-0642, Cornell repeats the same six references included in their April 2024 submission of Additional Materials, without offering any new evidence to support the safety of artificial turf. Notably, since their April submission, Cornell has failed to provide any additional materials beyond these twelve previously cited references. Of the six references reiterated, two studies (Peterson and Schneider) are industry-funded, while two EPA reports on tire-derived crumb rubber (TDCR) remain debated and only address TDCR infill, neglecting many other environmental and health concerns associated with artificial turf. Pavilionis et al.’s 2014 study is misrepresented limited in scope, and the 2018 Pronk study assesses safety only under controlled exposure conditions for sports use. In contrast, a more recent study by Armada et al. (2022) for example highlights broader environmental and cumulative human health risks, including microplastic pollution and the persistence of hazardous chemicals in the environment. Armada’s findings directly challenge the industry’s claims of "safe" rubber granules, particularly when considering long-term environmental impacts and microplastic accumulation. It makes one wonder where the “over 100 scientific, peer-reviewed, published studies” Cornell makes reference to on page 4 of their Memorandum are. ○ On R0642, “Reports on Artificial Turf,” Cornell mislabels the section title—it should be “Reports by Environmental Organizations.” Cornell dismisses the substantial reports from reputable groups—including Beyond Plastics, Plastic Pollution Coalition, Earthjustice, Icahn School of Medicine at Mount Sinai, Environmental Working Group, and PEER—as “impartial” while selectively citing the New York State Department of Health (NYSDOH) fact sheet on synthetic turf with TDRC infill to misrepresent its findings. The fact sheet does not conclude that health risks are negligible—it acknowledges uncertainties, data gaps, and the need for further research. NYSDOH explicitly states that crumb rubber contains known carcinogens and potential risks, particularly for children. Cornell distorts this by cherry-picking conclusions that align with its position while ignoring warnings about chemical exposure and environmental concerns. Cornell also downplays the severe heat hazards of synthetic turf, which the fact sheet clearly addresses. Moreover, the NYSDOH report touches on chemical leaching, runoff, and environmental persistence—issues Cornell conveniently omits. This selective framing misleads the public and ignores the full scope of concerns. ○ On R0642, Cornell’s claim on Carmona et al. (2023) is misleading. The study actually examines toxicity in recycled HDPE, not artificial turf, and was correctly placed under the section of "Failure of Plastic Recycling," not under “Scientific Studies on Artificial Turf.” ○ On R0642, Cornell describes Golijianin et al. (2024)’s study in this way:: “This study reviewed NFL injury rates between natural grass and synthetic turf fields and concluded that injury rates were higher when playing on synthetic turf fields. Given that NFL natural grass fields are maintained in pristine playing condition, it would be anticipated that injury rates on synthetic turf would be higher.” If even the NFL’s best-funded turf fails to match natural grass, what makes Cornell think theirs will be any different? ○ On R0642, Cornell makes a false claim on Kole et al. (2023) as “based on a literature review of mostly non-peer reviewed sources.” The peer-reviewed study was published in Science of the Total Environment, following systematic review protocols (PRISMA (Preferred Reporting Items for Systematic Reviews and Meta-Analyses) and GRADE (Grading of Recommendations, Assessment, Development, and Evaluation). ○ On R0642, Cornell misspells the name of the author Watterson as Waterson. Cornell also makes the false claim about this study as not peer-reviewed. Watterson’s 2024 study was published in Scientific Reports and it would have undergone peer review prior to publication. If Cornell University contends that this specific article was not peer-reviewed, we would like to seek clarification from them regarding the basis of their claim. ○ On R0642-0643, Cornell’s characterization of Winz et al. (2023) is misleading. The study found that chromium exceeded the inferred safety limit on the surface of tire crumb rubber playground tiles, while copper, arsenic, thallium, and antimony reached potentially harmful levels within three years. Cornell’s claim that "no risk to children would be present" because precipitation would wash metals away is not supported by the study. Winz et al. explicitly state that metals are continuously released to the surface over time, with some accumulating at concerning levels. The notion that rain will eliminate exposure risks is not only speculative but ignores the persistence of contamination and the potential for repeated dermal contact in playground environments. ○ On R0643, Cornell misrepresents the findings of Zuccaro et al.’s studies on tire-derived crumb rubber (TDCR) from 2022 and 2023 (R0643). Zuccaro’s 2024 article provides a more definitive analysis, highlighting the EU ban on TDCR infills and calling for similar bans elsewhere due to microplastic pollution concerns. This study was co-authored with the feature film “Dark Waters” real-life PFAS lawyer Robert Bilott. See the separate tab “Zuccaro” for details. Despite this, Cornell is still moving forward with plans to use crumb rubber in one of its synthetic fields. ○ The rest of R0643 and R0644 dismiss items in our bibliography as “NGO websites,” “journalistic coverage,” or reports that “focus on PFAS and plastic; not specific to synthetic turf”—as if synthetic turf is not plastic. These reports, however, are well-researched and highly credible, with journalistic coverage that meets rigorous investigative standards and reports that are as methodologically sound as peer-reviewed studies. We selected only the most authoritative sources. On Bans and Moratoriums, Cornell claims, “this content was addressed previously in this submission,” yet no such response addressing these bans and moratoriums can be found. Cornell never actually engaged with the issue of growing bans and moratoriums on synthetic turf but pretends they did to dismiss the topic without proper discussion. ● Cornell’s references on microplastics are entirely inadequate. They do not provide a single study directly addressing microplastic pollution from synthetic turf, except for De Haan et al. (2023), which they discuss only in response to our submitted bibliography rather than as part of their own evidence. Despite this, they claim on page 21 of their Memorandum to have submitted “extensive documentation from scientific studies and consultant analyses addressing the topic of microplastics.” However, the only reference they cite on that page is a two-page letter from Dr. Frank Rossi (R0622-0623), which contains zero references and no scientific analysis. Dr. Rossi has a documented conflict of interest (CoI) with the petrochemical company Petro-Canada, a fact highlighted in a recent public comment on a related case. See the “Rossi” tab for details. Additionally, the City Planning Board ignored a public comment submitted on September 26 that outlined the flaws in Dr. Rossi’s claims about microplastic filtration and called for a recall of the Negative Declaration. See the “On Filtration” tab for the full September 26 public comment. 2. Flawed and Inadequate Microplastics Mitigation Measures ● Cornell’s natural grass turf expert Frank Rossi with CoI with fossil fuel company proposes a 212-micron (0.212 millimeters) filtration system, which is woefully inadequate: ○ Microplastics and nanoplastics are often smaller than 1 micron. ○ Filtration only addresses water runoff but not airborne microplastics or particles tracked away on shoes and clothing. ○ This was addressed in the 9/26 public comment. ● Filtration systems themselves often contain PFAS, including PVDF, which are set to be banned in Europe due to health risks. ● Cornell ignores multiple studies we submitted citing synthetic turf as the significant source of microplastic pollution (De Haan et al. 2023, Zhu et al. 2024) The European Chemicals Agency’s (ECHA) warning that synthetic turf is the #1 source of microplastic pollution in Europe. (ECHA 2020). ● Toronto’s latest environmental study also flagged synthetic turf as the #1 contributor to microplastic pollution. (Zhu 2024). ● Cornell is located upstream from a major water source—meaning contaminants from synthetic turf will flow into the local lake, creeks, and drinking water. ● There is a substantial concern that microplastic contributes to HABs (Harmful Algal Bloom) in Cayuga Lake according to the latest studies. (Koizumi, 2024) 3. Misleading Claims on PFAS Compliance ● Cornell falsely claims that its “selected” synthetic turf will comply with New York’s PFAS-in-carpets law, despite lacking key details: ○ No manufacturer or product has been selected—Cornell has no basis to confirm compliance. ○ Independent testing has repeatedly found PFAS in turf products that claim to be “PFAS-free,” including in turf blades (Whitehead, 2023). Cornell has failed to respond to multiple public comments raising this issue. ○ New York’s carpet law defines PFAS broadly (OECD-level), meaning even trace amounts are significant. See the separate tab “OECD Definition of PFAS” for details. It simply is not possible that their synthetic turf complies with the NYS law. ○ The EPA has declared that there is NO safe level of PFOA and PFOS—the only safe level is zero. See the separate tab “OECD Definition of PFAS” for details. ● PFAS chemicals such as PVDF and PVDF-HFP are commonly used in synthetic turf manufacturing as slip agents to prevent blade defects during production. ● Cornell fails to specify who will conduct independent PFAS testing, what the threshold for compliance is, or if third-party oversight will be required. ● Given the broad definition of PFAS, Cornell must be required to test for the entire class of PFAS chemicals, not just select subsets. 4. Flawed Planning Board Process and Conflict of Interest ● The planning board chair whose deliverance is given much weight in the memorandum on page 7 had direct ties to Sasaki, a firm involved in synthetic turf projects. ○ He worked at Sasaki for 10 years in Watertown, Massachusetts, where Cornell’s project consultant Trey Sasser also works. See the tab “Rossi” for details. ○ He did not recuse himself despite this clear conflict of interest. See the tab “Rossi” for details. ● The approval process was rushed, with only four board members present (barely making quorum). ○ One member was brand new and likely did not review the nine months of submitted scientific evidence. ● The planning board’s discussion was limited only to PFAS and crumb rubber infill, ignoring concerns about microplastics, plant-based infills, and other toxic chemicals. 5. Cornell’s Heavy Reliance on Dr. Frank Rossi’s 2-page “Analysis” ● Cornell repeatedly cites a 2-page letter from Dr. Frank Rossi, a turfgrass expert with fossil fuel ties. ● The letter contains no references or citations and mentions European studies without naming them. ● Dr. Rossi is not an expert in microplastic pollution or environmental chemistry. He is a natural turf grass specialist. His Ph.D. from Cornell is in Plant Science and he teaches courses in horticulture, turfgrass science and food systems. ● He has documented financial ties to Petro-Canada, creating a conflict of interest. (See separate tab for Rossi for evidence). 6. Cornell’s Attempt to Dismiss Zero Waste Ithaca’s Standing ● 7 pages out of 30 of Cornell’s response focus on attacking Zero Waste Ithaca’s legal standing under Article 78, instead of addressing substantive environmental concerns. ZWI is incorporated. ● Cornell argues that only direct users of the field—not the broader community affected by pollution—should have standing. ● The City Planning Board should recognize the public health and environmental threats posed by this project. 7. Cornell’s Expansion Plans and Long-Term Impact ● Cornell already has 9 synthetic turf fields on campus on our count - 7 existing, and 2 under construction. See the separate tab for details. ● A 2015 document confirms their plans to build at least five more synthetic turf fields as part of their sports complex expansion. ● Approving any more synthetic field will set a dangerous precedent for more. ● Synthetic turf behaves like an invasive species, replacing natural ecosystems and spreading pollution. Conclusion Cornell’s legal memorandum is misleading, selective, and inadequate in addressing the serious environmental and health risks posed by its synthetic turf project. ● Their “100+ studies” claim on page 4 of Cornell’s Memorandum is deceptive—they submitted only 12 references, many of which are outdated or industry-funded. ● They misrepresent microplastic risks and propose an ineffective 212-micron filtration system. ● Their claim of PFAS compliance is unverified, as no product has been selected or tested. ● The planning board approval process was compromised due to conflicts of interest and lack of expertise. They repeatedly cite Dr. Frank Rossi, who lacks relevant expertise and has fossil fuel ties. ● Their legal argument prioritizes procedural technicalities over public health and environmental protection. This case clearly meets the threshold under SEQRA for an Environmental Impact Statement (EIS) because: ● There is substantial scientific debate and uncertainty about the safety of synthetic turf. ● Cornell is located upstream from a major water supply, increasing environmental risks. ● New studies on microplastic pollution, PFAS, and toxic chemicals in plastics emerge regularly—yet Cornell ignores them. Cornell’s memorandum fails to justify their project on legal, scientific, and ethical grounds. The court must require a full Environmental Impact Statement (EIS) to assess the real risks. MICROPLASTICS: Respondents assert that they have “submitted extensive documentation from scientific studies” about microplastics. (NYSCEF Doc. No. 43 at 21.) However, this claim is misleading, as the record indicates that only one letter from Respondents' own employee, Dr. Frank Rossi, addressed microplastics. (R0622-23.) Dr. Rossi is a turfgrass expert with no demonstrated expertise in plastic chemistry, microplastic pollution, or polymer science. His two-page letter, which Respondents call an “analysis,” does not cite a single named study on microplastics and focuses primarily on the necessity of synthetic turf rather than its environmental impacts. In contrast, ZWI submitted over 70 pages of peer-reviewed studies from credible environmental journals and authoritative sources demonstrating that synthetic turf is a major contributor to microplastic pollution. (NYSCEF Doc. No. 20 at 33.) These studies confirm that microplastic particles from synthetic turf persist in the environment, contaminate waterways, accumulate in the food chain, and pose long-term ecological and human health risks. (Zhu et al. 2024, De Haan et al. 2023, ECHA 2020.) Cornell’s proposed mitigation measure—a 212-micron mechanical filtration system—is scientifically meaningless. Microplastics and nanoplastics are often smaller than 1 micron— hundreds of times smaller than Cornell’s filter threshold. (Park et al. 2022.) Scientists working on microplastic removal target submicron filtration (under 1 micron) or, at minimum, 40 microns, far below Cornell’s ineffective 212-micron threshold. (Chand et al. 2024.) Furthermore, Cornell’s plan does nothing to prevent airborne microplastics—one of the primary pathways of human exposure. The EPA’s 2024 findings confirm that synthetic turf users routinely carry microplastics on their skin, shoes, and clothing, dispersing them into homes, cars, and water systems. (R1700.) Compounding the risk, microplastics from synthetic turf contain water-soluble toxic chemicals— including PFAS, VOCs, and heavy metals such as cadmium, mercury, and lead. (Silva et al. 2021.) New research indicates that microplastics combined with PFAS are even more toxic than previously understood. (Huang et al. 2025.) While Cornell claims its turf will be “PFAS-free,” it provides no manufacturer details, no accountability for independent testing and reviews, and no threshold criteria to substantiate this claim. Under New York’s carpet law, PFAS is broadly defined, as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom,” aligning with OECD standards—making it nearly impossible for any synthetic turf manufacturer to prove a truly PFAS-free product. (Wang 2021, NYS Open Legislation https://www.nysenate.gov/legislation/laws/ENV/27-3301.) The EPA in 2024 documented that the majority of people who had used synthetic turf fields found synthetic turf infill on their person, in their cars, and in their homes after leaving the field. (R1700.) This demonstrates the difficulty—and near futility—of preventing microplastics from spreading into the environment once synthetic turf is installed. The 2024 PEER study further confirms that PFAS contamination from synthetic turf is transferred onto players' hands, with levels significantly higher than those on natural grass fields. (PEER 2024.) Additionally, a June 2024 study in Environment International found that PFAS compounds can be absorbed through human skin, reinforcing the risks of direct exposure. (Ragnarsdóttir, Abdallah, and Harrad 2024.) These findings directly contradict Respondents’ claims that PFAS exposure via synthetic turf is negligible. SEQRA requires agencies to take a “Hard Look” at environmental risks before issuing a Negative Declaration. The Planning Board’s failure to meaningfully evaluate these concerns— and its reliance on an unverified, two-page letter from a non-expert instead of extensive independent research—renders its decision arbitrary and capricious. Given the overwhelming evidence that synthetic turf contributes to microplastic and PFAS pollution, an Environmental Impact Statement (EIS) is legally required. AIR EMISSIONS AND VOCs. Despite Respondents’ contentions, the record lacks scientific studies demonstrating a consensus that emissions and VOCs from synthetic turf fields pose no health risks. Instead, multiple studies show that synthetic turf releases harmful airborne pollutants, especially in enclosed spaces. Respondents cite a 2018 New York State Department of Health Guidance Document, claiming that exposure to VOCs, SVOCs, and airborne particulate matter from synthetic turf is “insignificant” and comparable to natural grass. (NYSCEF Doc. No. 43 at 21-22.) However, they fail to include the part of the study that states that when synthetic turf is installed indoors, VOC and particulate concentrations are significantly higher than outdoor fields. (R3152.) Recent studies further confirm the risks associated with airborne microplastics and VOCs. The 2023 Center for International Environmental Law (CIEL) report highlights the growing crisis of airborne microplastics from synthetic turf, which are inhaled and linked to respiratory and cardiovascular diseases. (CIEL 2023.) Additionally, studies such as Mohammed et al. (2023) confirm that synthetic turf releases VOCs at higher levels in warmer temperatures, raising cancer risks, particularly for children. (Mohammed et al. 2023.) Phthalates, commonly used as plasticizers in synthetic turf backing and infill, are also released into the air, posing endocrine- disrupting risks and linked to reproductive and developmental issues in children. (Negev et al. 2022.) Indoor synthetic turf installations pose even greater risks. Studies such as Abad López et al. (2023) show that airborne microplastics in enclosed environments accumulate and are inhaled at much higher rates due to limited ventilation. (Abad López et al. 2023.) These microscopic plastic particles penetrate deep into the lungs, increasing risks of inflammation, chronic respiratory diseases, and cardiovascular issues. (Aini et al. 2022.) The Huang et al. (2023) study on EPFRs (environmentally persistent free radicals) in crumb rubber infill further confirms that exposure can lead to oxidative stress and respiratory complications. Crucially, ventilation systems do not effectively capture or neutralize these nanoparticles, allowing them to circulate freely in the air. Cornell’s memorandum selectively omits these risks while relying on outdated assessments and misrepresenting studies. SEQRA requires agencies to take a “Hard Look” at environmental impacts, yet the Planning Board dismissed peer-reviewed evidence on VOC emissions and inhalation risks in favor of an incomplete summary from Respondents. This failure to meaningfully engage with scientific research constitutes an arbitrary and capricious decision requiring an Environmental Impact Statement (EIS). B. The Negative Declaration Relies on the Respondent’s Future Actions Making It Conditional The Planning Board's reliance on future actions and mitigation measures to justify foregoing an Environmental Impact Statement (EIS) is legally impermissible. Respondents cite W. Beekmantown Neigh. Ass’n Inc. and Merson v. McNally to argue that project modifications made in response to public concerns do not amount to an impermissible conditional Negative Declaration. However, these cases do not support the Planning Board’s failure to require an EIS in this instance. In W. Beekmantown Neigh. Ass’n Inc., the court upheld mitigation measures only because an EIS had already been completed (861 N.Y.S.2d at 866)—a crucial distinction from the present case, where no EIS was conducted at all. Similarly, in Merson v. McNally, the court found that minor mitigation—such as adding an additional two feet of buffer space (90 N.Y.2d 742, 755 (1995))—did not require an EIS. Here, however, the proposed mitigation measures—such as stormwater filtration to prevent microplastic pollution—are not minor adjustments but central to the project’s environmental impact. Moreover, SEQRA regulations explicitly prohibit lead agencies from using mitigation measures as a substitute for full environmental review where potential adverse environmental impacts exist. Courts have consistently held that agencies cannot defer analysis by assuming that mitigation efforts will fully eliminate environmental harm (Matter of Farrington Close Condominium Bd. of Managers v. Incorp. Vill. of Southampton, 205 AD2d 623, 626 (2d Dep’t 1994); Matter of Cannon v. Murphy, 196 AD2d 498, 501 (2d Dep’t 1993)). The Planning Board’s Negative Declaration does exactly that—it assumes that mitigation efforts will be sufficient but fails to require a full environmental assessment to determine whether they actually will be. Courts have invalidated Negative Declarations where mitigation measures are treated as a substitute for actual impact assessment rather than being incorporated into a properly reviewed project. (See, e.g., Cathedral Church of St. John the Divine v. Dorm. Auth. of State of N.Y., 224 A.D.2d 95, 102-03 (3d Dep’t 1996) (holding that mitigation measures cannot be used to evade SEQRA’s EIS requirement)). Unlike the minor modifications in Merson, the entire foundation of Cornell’s microplastic and PFAS risk assessment is based on untested mitigation efforts that were never subjected to an EIS review. By relying on mitigation measures instead of requiring a proper environmental review, the Planning Board’s decision was arbitrary, capricious, and in direct violation of SEQRA. The law does not permit agencies to assume that mitigation will eliminate potential harms - it requires them to analyze those harms first. From: To: Cc: Subject: Sent: Constance Stirling-Engman Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org Synthetic Turf issue, Town Planning Board March 18, 2025 3/17/2025 4:22:32 PM **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department Dear Town Planning Board Members, The August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I am also sharing a link to a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification.This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee.Additionally, I want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment.Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Constance Stirling-Engman References: 1. Lowell Center for Sustainable Production, University of Massachusetts Lowell. Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf: Academic, Municipal, and Other Testing Efforts. August 2024. https://www.dropbox.com/scl/fi/iu0089u8nxv3bsen6xuoo/PFAS-in- Artificial-Turf-Academic-Municipal-Other-Tests-Aug-2024_tcm18- 386957.pdf?rlkey=ggh2ceiuiyt7rr6yy8ij1dnzd&st=46tixd3p&dl=0. The compilation of PFAS testing from academic, municipal, and independent studies confirms that PFAS have been detected in all components of artificial turf, including turf blades, carpet backing, infill, shock pads, adhesives, and even product packaging. Total fluorine (TF) testing consistently found fluorine across various samples, with concentrations ranging from 16 to 661 µg/g (ppm), suggesting the widespread use of polymeric PFAS, fluorinated coatings, or PFAS-based processing aids. Extractable PFAS tests detected long- and short-chain PFAS in multiple studies, particularly fluorotelomer alcohols (FTOHs) in crumb rubber infill, perfluoroalkyl acids (PFAAs) in turf fibers, and PFAS precursors in adhesives and shock pads. Municipal and nonprofit-led testing further corroborates these findings, with PFAS measured in stormwater runoff, installation materials, and artificial turf fields marketed as ‘PFAS-free.’ These results highlight significant gaps in industry claims and emphasize the need for stricter regulations and improved testing methodologies to assess the full extent of PFAS contamination in artificial turf systems. 2. Berghaus, E. Declaration for FieldTurf/Tarkett Sports Regarding the Manufacturing of Artificial Turf Filaments. Letter sent to City of Portsmouth, NH. October 22, 2019. https://nontoxicdovernh.files.wordpress.com/2020/03/met-pfas- statement-fieldturf-1.pdf A supplier for FieldTurf/Tarkett Sports claims that their artificial turf filaments/fibers are fluorine-free and do not contain PFAS, including PFOS, based on manufacturing consistency and compliance with REACH regulations. However, the declaration lacks total fluorine testing, does not specify PFAS detection limits, and does not test the full turf system, meaning polymeric PFAS or precursors could still be present. Additionally, there is no independent third-party verification, making the PFAS-free claim scientifically weak and incomplete. 3. Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Zero Waste Ithaca Bibliography. Updated March 16, 2025 https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM- s_4bfbmO26R-Q/edit?usp=sharing Subject: TenCate’s Synthetic Turf: Pesticide Use, Microplastic Pollution, and ExxonMobil Ties Contradict Cornell’s Sustainability Claims Dear Town Planning Board Members, Cornell University has selected TenCate as the manufacturer for its planned “PFAS-free” synthetic turf field on Game Farm Road. However, the university’s claims of environmental sustainability are contradicted by TenCate’s own maintenance guidelines and troubling industry practices. First, despite Cornell’s repeated assertions that synthetic turf eliminates the need for herbicides, TenCate’s 2024 Maintenance Manual explicitly allows only the use of Spectracide and Roundup—both known carcinogens—for weed control. This directly contradicts statements made by Cornell chemist Brett P. Fors at the March 4, 2025, Town Planning Board meeting, where he falsely claimed that synthetic turf requires no pesticides. The manufacturer’s own documentation proves otherwise. See Page 15 of the manual of “Approved System Components.” Second, TenCate’s artificial turf is demonstrably prone to fragmentation, releasing microplastics into the environment. A video recorded on February 4, 2025, by Pamela Bond in San Jose, California, shows TenCate’s Pivot synthetic turf failing within just three months of installation. Turf blades were visibly breaking down, shedding microplastic fibers into the environment—undermining industry claims that synthetic turf prevents pollution. Third, TenCate’s partnership with ExxonMobil further exposes the company’s role in environmental harm. TenCate sends used synthetic turf to ExxonMobil’s Baytown, Texas, facility for so-called 'advanced recycling' (i.e., pyrolysis), a process widely criticized for inefficiency, high emissions, and environmental justice concerns. As documented by Dr. Neil Carman in his June 25, 2024, letter to the City of Ithaca Planning Board, communities near Exxon’s Baytown complex have been fighting toxic pollution for decades. The addition of synthetic turf waste processing only exacerbates the environmental burden on these already overburdened communities. Additionally, TenCate’s home country, the Netherlands, is moving away from artificial turf, as evidenced by the Eredivisie’s decision to ban synthetic turf starting in the 2025–26 season. This marks a major shift in Dutch professional football, where all clubs in the Eredivisie and Keuken Kampioen Divisie will be required to play on natural grass or hybrid pitches. The decision, made unanimously by the leagues, is the result of a long-term transition that began in 2018 and aligns with broader European efforts to phase out artificial turf. As a Dutch-based company, TenCate now finds its own country rejecting the very product it promotes, signaling a growing recognition of artificial turf’s drawbacks, including concerns over player safety, environmental impact, and game quality. Cornell’s selection of TenCate as a synthetic turf supplier raises serious concerns: ● No independent PFAS testing has been conducted on TenCate’s products under full public oversight. ● TenCate’s own manual permits herbicide use, refuting Cornell’s pesticide-free claims. ● Documented premature degradation of TenCate turf contradicts industry promises about durability and environmental safety. ● TenCate’s involvement with ExxonMobil’s chemical recycling scheme ties Cornell’s project to a deeply flawed and polluting industry practice. The evidence is clear: Cornell’s claims about synthetic turf sustainability are misleading. The university cannot ignore the environmental and public health consequences of choosing TenCate as its turf supplier. Sincerely, Analyse Adams Food & Water Watch Volunteer References: ● Pamela Bond, John Mise Park, San Jose, CA: TenCate Pivot Turf Failure (Video, February 4, 2025). A video shared by a grassroots activist in California. https://share.icloud.com/photos/06b1nGfaanJ6PyjxN0sXMdtNQ ● Dr. Neil Carman, Letter to the City of Ithaca Planning Board, June 25, 2024. https://drive.google.com/file/d/17Hjoae7HMpXo3ueK92Auq71sJXXhsDUT/view?usp=sharing ● TenCate Americas, TenCate Pivot 2024 Maintenance Manual V1 (Dayton, TN: TenCate Americas, 2024). https://www.dropbox.com/scl/fi/povlnuhbuh5qy1lbjq5jx/TenCate-Pivot-2024-Maintenance-Manu al-V1.pdf?rlkey=ui10g16wenrdrjgy05rpyeidk&st=5l74l8dw&dl=0 ● Alexander H. Tullo, "ExxonMobil Will Recycle Synthetic Turf," Chemical & Engineering News, October 1, 2022. https://cen.acs.org/environment/recycling/ExxonMobil-recycle-synthetic-turf/100/i35 ● James Bruggers, “In Houston, a City Council Member Questions ‘Advanced’ Recycling of Plastic and a City Collaboration with ExxonMobil.” Inside Climate News. December 13, 2024. https://insideclimatenews.org/news/13122024/houston-city-council-member-questions-exxonmob il-plastic-recycling/ ● Eredivisie. "No More Artificial Turf in the Eredivisie from the 2025-26 Season." Eredivisie, May 28, 2024. https://eredivisie.eu/news/no-more-artificial-turf-in-the-eredivisie-from-the-2025-26-season/. Dear members of the Town of Ithaca Planning Board, Cornell University makes high claims of having a Climate Action Plan that puts it in the forefront of institutions of higher learning taking on the challenges of dealing with climate change. Should we not expect that its actions would follow its words? It appears that it did not live up to its claims when it lobbied to build the Meinig Field House and adjacent field using artificial turf, also known as synturf. Synturf has been documented by reliable scientific sources to contain forever chemicals (PFAS), micro plastic particlesand other harmful substances that make their way into the bodies of young athletes playing on them and into the surrounding environment, thus affecting the residents of the town of Ithaca. How is it that Cornell, a prestigious university with faculty members in the sciences of world renown, would take on such a project as this based on the advice of a firm with ties to the fossil fuel industry whose actions have been key to causing the climate catastrophe we are currently enduring and that has supplied Cornell with misinformation about their product? Why then is Cornell continuing to rely on false information while proposing to replace yet another grass playing field with synturf, this time the Game Farm Road Field Hockey field? Cornell’s recent claims make additional unreliable assertions. It claims that it will somehow procure the first PFAS-free artificial turf product ever produced: But Cornell can provide no evidence for that claim. The Board asked it to provide 3rd-party testing to show the chemical composition of its product. It could not provide that testing. Instead, it only provided its manufacturer's claim that the product will not contain "intentionally-added PFAS." As the Board knows know from its own correspondence with experts like Dr. Genoa Warner, it is not enough to rely on manufacturer's claims. Just because Cornell says its product will comply with NY State's Carpet Law does not mean its product will be PFAS-free. All the evidence before the Board-- from both the research literature and the applicant's own materials on the Meinig Fieldhouse Project -- show PFAS in turf blades, foam backings, and/or bonding agents. Will the Board reject all available evidence and instead swallow whole Cornell's claim that it will somehow produce PFAS-free turf product: a claim for which it could not provide the requested 3rd-party testing evidence? Can the Planning Board buy Cornell’s “story” while ignoring what diligent, well-informed members of the community have presented about its harms? Can it in good conscience dismiss the extraordinary work of these citizens who have, in essence, done much of the homework for it to provide scientifically reliable information about synturf? Does the planning board wish to be complicit in causing harm to the young athletes who have no idea what health problems they are bound to experience later in life? Does the Planning Board bear no responsibility to the community members who run similar health risks due to the PFAS and microplastics that will enter the environment and ultimately affect their health? How can the Town Planning board, charged with making decisions in the interest of the health and well-being of its residents, accept the information presented by Cornell without demanding an EIS? Will the planning board swallow Cornell’s false claim that the Hockey field is not related to the Meinig Field house project ( in a move known as segmentation) to avoid the necessity to subject it to an EIS? Why would the Planning Board hesitate for a moment to insist that this project be subjected to the full SEQRA process. To whom is the Planning Board responsible? Cornell, the corporation, or the current and future residents of the town of Ithaca, including the Cornell student athletes. Do you not have the moral duty to serve and protect them all using the most effective tools at your disposal? I sincerely hope that your answers to my questions will lead you to insist that this project undergo an EIS before you would even consider to allow it to go forward. Respectfully yours, Elisa Evett Statement on Synthetic Turf and the Plastics Industry Brian Eden, Policy Coordinator, Campaign for Renewable Energy March 18, 2025 Thank you for providing thoughtful attention to my concerns. I wish to present a critical argument against the proposed project involving synthetic turf and the increasing reliance of the fossil fuel industry on plastics. The fossil fuel industry has actively promoted the plastics market as a growth area to maintain profitability, using petrochemicals as a key feedstock for plastics production. As the world transitions toward renewable energy and away from fossil fuels, the industry has sought to sustain demand by expanding the plastics market. We must ask ourselves: Would humans, on their own initiative, choose to replace natural vegetation with plastics? This project is fundamentally unsustainable. It involves contaminating a green field with plastics and other chemicals, exposing athletes to microplastics that will contribute to their already growing lifetime body burden, and unnecessarily exacerbating greenhouse gas emissions. Scientific research has increasingly demonstrated the dangers of microplastics. As I referenced in an earlier submitted comment, a New York Times op-ed, Our Way of Life is Killing Us, highlighted the widespread detection of microplastics in human blood, lungs, liver, heart, and brain tissue. This project will undoubtedly contribute to this looming health crisis. Are any Planning Board members willing to take action and slow the flow of plastics into our environment? Despite our concerns, our request for a meeting with the Athletic Director was denied. The University's response suggested that the Planning Board was the only relevant party of interest to them. In my experience, the University has been unwilling to engage or collaborate with the community on critical environmental issues. As an educational institution, should it not be Cornell’s responsibility to provide student-athletes with balanced information about this project? Instead, these students and their parents appear completely unaware of the complex environmental, health, and climate implications of this project. Additionally, some Board members seemed to provide significant weight to the assertion that synthetic turf fields would benefit athletes’ mental health. If this was such a determinative factor, why was no scientific evidence presented to support this claim? In an earlier comment, I also raised the issue of excess Scope 3 greenhouse gas emissions resulting from the extraction of raw materials and the intense energy consumption required for plastics production. Section 7(2) of the NY Climate Act requires state agencies to consider whether their actions, including permits and other administrative approvals, are inconsistent with or interfere with the attainment of statewide greenhouse gas emissions limits, and to provide justification and mitigation measures if deemed inconsistent. This principle should be applied in this review. However, the Planning Board did not even consider this issue when producing the finding on Impacts on Energy in the SEQR Part 3 review. It is not surprising that a predominantly privileged Board would disregard these emissions, as those most adversely affected tend to live in disadvantaged communities. In the developed world, we protect ourselves through infrastructure upgrades, technological advancements, and policy changes, while disadvantaged communities often face greater vulnerability and require targeted support and adaptation strategies. Historically, Americans have been among the planet’s major per capita contributors of greenhouse gases. Another concerning omission from this review is the lack of participation from Cornell’s Office of Sustainability. Why has this office, which specializes in campus environmental matters, not been engaged in any of these synthetic turf reviews conducted so far? Cornell’s own sustainability vision states: “We envision Cornell University as a carbon-neutral, living laboratory for sustainability innovation; a place where every Cornellian can make a positive impact on social, environmental, and economic progress.” While objective criteria exist for determining significant environmental impacts, the weight given to criteria such as magnitude and duration, by Planning Board members may be subjective. The review focuses on individual topics rather than on cumulative impacts. What is the cumulative impact of many entities making incrementally harmful decisions? We are witnessing the impending rollback of fifty years of environmental protections under the Trump Administration, which dismissed climate science as a hoax. The Planning Board’s review of this project seems to fall somewhere between this deregulatory stance and the expressed concerns of the local environmental community. We offer a different perspective than the Trump Administration—one grounded in scientific literacy and social responsibility. We urge the Planning Board to aspire to apply these values in this review For the third consecutive review of synthetic turf projects (including the Ithaca College project), it appears that the Board is prepared to dismiss community concerns. Board members have yet to demonstrate a full understanding of the science involved. Are we doomed to repeat this controversial process indefinitely with each subsequent request to install a synthetic turf field? The Board possess a crucial tool at its disposal: an Environmental Impact Study (EIS). The need for such a study in the Town is infrequent, yet this project clearly demands one. New York State has provided this tool for Planning Boards to apply in this type of complex circumstance. Why does the Board continue to reject the use of this essential tool? When was the last time an EIS was utilized by this Board? Why does the Board persist in disregarding the concerns of its own community members? Board members should decide this crucial matter as if they were our neighbors. As the community’s last line of defense, I urge the Board to reconsider its approach, prioritize environmental and public health concerns, issue a Positive Declaration, and conduct an Environmental Impact Study before making any further decision to approve this project. The stakes are too high to ignore the need for a more comprehensive review. Dear Town Planning Board Members, The attached August 2024 report from the University of Massachusetts Lowell confirms that PFAS have been detected in all components of artificial turf, including blades, backing, infill, shock pads, adhesives, and even product packaging. Despite Cornell University’s claims that its field hockey turf is different because it lacks infill, this report demonstrates that PFAS contamination is not limited to infill alone. However, this study, conducted by a respected research center with full citations and expert analysis, is highly relevant to the town planning board’s review. Declaring a negative declaration without considering this research is a failure of due diligence. It is also deeply problematic that Cornell seeks to control the narrative by discounting high-quality investigative journalism and research from credible organizations—especially in a rapidly evolving field where new findings emerge constantly. I am so grateful for to see the studies that ZWI have provided our community from their legitimate, scholarly research that exhibits how horrifying this turf project is. CAN YOU LIFT YOUR HEAD OUT OF CORNELL’S DECEPTION AND SEE IT? WE WILL NOT STAND FOR THIS!!!!! Cornell characteristically dismisses reports like this as “non-peer-reviewed” NGO materials. It’s absolutely beyond the pale that this institution that proclaims itself as a leader in scientific research would represent themselves in such a horrifying manner. TRULY. Additionally, some artificial turf manufacturers have marketed their products as “PFAS-free,” but testing in this report reveals PFAS were still found in those materials. This raises serious concerns about the validity of PFAS-free claims and the broader regulatory loopholes that allow these chemicals to go unreported. I appeal to each of you on this board who have shown your interest and dedication to making Ithaca healthy and safe. I know who you are, and I want you to use your voice to REQUEST a deeper study goes into this. DO NOT let Cornell bully you! I am also attaching a PDF from FieldTurf, in which they claim that one of their synthetic turf products is PFAS-free. However, this guarantee does not inspire confidence for several reasons. First, FieldTurf does not provide total fluorine (TF) testing, which is critical for detecting hidden PFAS, including polymeric PFAS and precursors. Second, they do not specify detection limits for their PFAS tests—without knowing how sensitive their tests were, we cannot assess the credibility of their claim. Third, their methodology likely focuses only on a small subset of PFAS chemicals, ignoring precursors and polymeric forms that may degrade over time into more hazardous compounds. Lastly, without third-party, independent verification, this statement is just a self-reported manufacturer claim rather than a rigorous PFAS-free certification. This raises an important question: What kind of PFAS-free guarantee does TenCate—the manufacturer of Cornell’s new field hockey turf—provide? The planning board must obtain and critically evaluate TenCate’s PFAS-free claims, including their detection thresholds, test methods, and whether they include total organic fluorine (TOF) and total oxidizable precursors (TOP) testing. Without this information, the board has not taken the "hard look" required under SEQRA. Given that PFAS have been found in artificial turf products marketed as "PFAS-free," it is reckless to assume that Cornell’s turf is truly PFAS-free without independently verifying TenCate’s guarantee. I also want to note that these reports have been included in Zero Waste Ithaca's bibliography under the "Independent Testing of PFAS" section all along. It is disappointing that the town planning board is moving forward with a Negative Declaration for the EIA despite these submissions, appearing to yield to political pressure from Cornell University rather than prioritizing scientific integrity and the protection of our community’s health and environment. And one last piece: Cornell also plans to do “independent” testing in addition to the manufacturer’s “PFAS-free” guarantee, but the testing will be done before it leaves the manufacturer, with zero specifications about testing method, threshold, etc - really confidence inspiring, according to page 10 of Supplemental Materials Submission dated January 31, 2025. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Do what’s right, people. THIS REQUIRES A COMPLETE ASSESSMENT! Sincerely, Caroline Ashurst Subject: Public Comment on Cornell University's Synthetic Turf Recycling Claims Cornell University’s claim that its synthetic turf will be recycled at the end of its life is misleading and lacks a credible plan. In the January 31st Supplemental Material Submissions (page 12), Cornell states that it is "committed to recycling" and lists two possible facilities for processing the turf: 1. Turf Recycler in Rockland, Massachusetts – This facility does not even exist yet, meaning there is no way to verify its operations, practices, or even if it will be functional when Cornell’s turf needs disposal. 2. Return Reclamation Program in Dalton, Georgia – Dalton is notorious for PFAS contamination lawsuits and is known as the "carpet capital of the world," a title linked to the widespread use of PFAS chemicals in synthetic carpets—including synthetic turf. The city of Dalton itself has filed lawsuits against major carpet manufacturers, alleging that their operations have contaminated the local water supply with PFAS. Recent legal actions in Dalton expose the environmental risks tied to synthetic turf recycling in this region: ● On December 10, 2024, the City of Dalton sued Shaw Industries, one of the largest carpet manufacturers, for PFAS contamination in the municipal sewage system. See: https://phillipslaw.com/pfas-lawyer/georgia-shaw-industries-and-3m/ ● Mohawk Industries, another Dalton-based manufacturer, has sued 3M and other chemical suppliers, claiming they concealed the environmental and health risks of PFAS chemicals used in carpet and turf production. See: https://www.atlantanewsfirst.com/2024/12/10/erin-brockovich-you-have-pfas-contamination-its-b ig-one/ ● Murray County, GA, has also filed a lawsuit against carpet manufacturers, holding them responsible for PFAS water contamination. See: https://www.atlantanewsfirst.com/2025/01/23/county-blames-chemical-maker-manufacturer-cont amination/ ● Meanwhile, a Georgia state lawmaker has proposed House Bill 211 ("PFAS Receiver Shield Act") to grant immunity to carpet manufacturers from litigation related to PFAS pollution, a move that has drawn sharp criticism from environmental advocates. See: https://www.atlantanewsfirst.com/2025/03/03/gop-lawmakers-want-carpet-manufacturers-protect ed-contamination-lawsuits/ turf Why is Cornell even considering a PFAS-contaminated region for its synthetic turf recycling? This raises serious concerns about the university’s lack of due diligence and the credibility of its recycling commitments. This vague and unverified recycling plan is not confidence-inspiring, especially given the history of misleading claims about artificial turf recycling. In the previous Meinig ‘Fieldhouse’ project with two synthetic turf , Cornell had suggested sending turf to Artificial Grass Recyclers (AGR)—a company whose listed locations do not appear to exist. Please see a separate pdf for my notes about AGR locations. Investigations into AGR’s listed addresses found that many were either vacant lots, residential complexes, or unrelated businesses. Additionally, Cornell has suggested Returf in North Carolina, another facility that is hundreds of miles away, raising logistical and environmental concerns. Transporting synthetic turf thousands of miles for questionable recycling solutions does not align with sustainable waste management principles. Cornell’s chosen turf brand, TenCate, further exposes the contradictions in its sustainability claims. TenCate promotes chemical recycling of synthetic turf in Baytown, Texas—a facility fiercely opposed by local communities due to its high emissions, toxic pollution, and environmental justice concerns. Chemical recycling is not a proven or scalable solution for synthetic turf disposal, and the process itself generates significant contamination. Another public comment was submitted on this issue. Adding to the concerns is Cornell chemist Brett P. Fors, who spoke at the March 4 Town Planning Board meeting, advocating for synthetic turf while failing to disclose his own conflict of interest. Fors has at least one pending patent application for chemical recycling technology, making his endorsement of plastic synthetic turf highly questionable. (See below screenshot, with a link for B.P.F.’s study and a note about pending patent application). https://www.nature.com/articles/s41586-024-08386-w#citeas Moreover, his lab receives funding from the U.S. Department of Energy (https://as.cornell.edu/news/energy-center-receives-126-million-renewed-funding), which has been linked to research benefiting the fossil fuel industry—a conflict recently exposed in a recent investigation by Grist. (https://grist.org/accountability/energy-department-american-chemistry-council-chemical-recycling/) Given the lack of a credible recycling plan, the significant conflicts of interest, and the environmental justice concerns surrounding chemical recycling, Cornell’s claims about synthetic turf sustainability should not be taken at face value. The Planning Board seems to have failed to inquire into these serious issues while proceeding toward a negative declaration in the environmental impact assessment. We strongly demand a full Generic Environmental Impact Statement (GEIS) to thoroughly evaluate the long-term consequences of this entire Game Farm Road site project before any approval is granted. Hereby, we have submitted this evidence for your review, ensuring that the record reflects these critical findings, which you are choosing to disregard as you move forward with a Negative Declaration. Sincerely, Carver Hauptman Additional References: Butler, Megan. “Panel Asked to Hold Georgia’s ‘Carpet Capital’ Liable for Contaminated Drinking Water.” Courthouse News Service. September 13, 2022. https://www.courthousenews.com/panel-asked-to-hold-georgias-carpet-capital-liable-for-contami nated-drinking-water/. About a lawsuit on PFAS contamination in Dalton, GA, the “Carpet Capital of the world.” Artificial Grass Recyclers https://artificialgrassrecyclers.com/site-locations/ Site accessed in December 2024. Opaque Operations - no phone number for any of the couple of dozens of locations except for the three listed on the “Site Locations” page of AGR in Sacramento, CA, Rockwall, TX and Peoria, AZ. You have to request for directions in order to find address of each location. And when you dig a little deeper on Google Map to ascertain locations, we found out that they actually do not have any locations in many of these places. We checked up to 6 of them and they were all faulty addresses. AGR, Media, PA We tried to find information about the closest AGR location in PA, and a search on Google Map for “artificial grass recycler” in Media, PA is supposed to be located at AGR, 101 E Baltimore Ave, Media, PA 19063, USA according to the company’s page but when we checked Google Map, it leads to US Post Office address. https://artificialgrassrecyclers.com/site-locations/ (Checked on Dec. 2024) AGR, Thurmont, MD Same issue with AGR’s Thurmont, MD location … 15 E. Main Street, Thurmont, MD. is a closed tavern. AGR, Woodbridge, VA Same issue with their 1761 River Bend Way, Woodbridge, VA 22192 location - it appears to be a residential complex. AGR, Smithfield, VA Their 15 S Church St, Smithfield, VA 23430 location seems to be a lawn in a quaint neighborhood with B&B and church nearby. We don’t see any office or recycling facility. AGR, Fayetteville, NC This location is an apartment complex called Edward’s Place. AGR, Temecula, CA 44830 Vía Pino, Temecula, CA 92590 Seems like a personal residence rather than a recycling facility. AGR, Murrieta, CA (Permanently Closed Location) Shots from April 2024? 25800 Washington Ave Murrieta, CA 92562-9748 (951) 216-7282 APN#000227410 Property/tax records not found ? Connection to Turf Distributors, Temecula (new ST; left over stock) Visit Website Screenshot from April, 2021 AGR, West Sacramento 1876 S River Rd, West Sacramento, CA 95691 tel. 925-259-3474 tel. 855-409-4247 AGR, 4452 TX-276, Rockwall, TX 75032 See the tall piles of artificial turf languishing outdoors - in an enormous area according to the Google Map. Returf, North Carolina 1906 West Front Street Statesville, NC 28677 https://returf.com From: To: Cc: Subject: Sent: Sasha K-R Town Of Ithaca Planning pbstaﬀ@cityoﬁthaca.org Letter from local Ellis Hollow residents opposing Artiﬁcial Turf 3/18/2025 10:48:41 AM **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 March 16, 2025 Town of Ithaca Planning Board 215 N Tioga St. Ithaca, NY 14850 Dear Members of the Town Planning Board, We are writing to express our strong opposition to Cornell University’s plan to expand synthetic turf fields in the adjacent area. As longtime residents of Ellis Hollow Road and the operators of Edible Acres, a permaculture nursery, we are deeply concerned about the environmental and public health risks posed by these artificial turf fields and other developments in the area—particularly their contribution to PFAS contamination, microplastic pollution, long-term ecosystem damage, and the broader harm caused throughout the plastic lifecycle, both nationally and globally. PFAS, also known as “forever chemicals” due to their persistence and accumulation in the environment, pose serious risks to water, soil, and human health. No level of PFAS exposure is considered safe, and even minute amounts build up over time, contaminating our shared environment and threatening our community garden and local water sources. Cornell’s plan lacks meaningful long-term accountability. While they now claim only three synthetic fields will be installed, without a Generic Environmental Impact Statement (GEIS), there is no legal obligation preventing further expansion. Given the university’s significant financial ties to fossil fuel companies and plastic research with pending patents, we have little confidence in their commitment to true sustainability. This project directly contradicts Cornell’s stated climate goals and will set a dangerous precedent for other institutions. This is an opportunity for the Town Planning Board to demonstrate its integrity and leadership by rejecting a project that prioritizes corporate and institutional interests over public health and environmental responsibility. Issuing a positive declaration for an environmental impact assessment and requiring a GEIS will show that Ithaca is a true beacon for environmental justice. We urge the Town Planning Board to reject further synthetic turf development and instead advocate for preserving this land as a natural area with trails and fields that support biodiversity rather than plastic-covered landscapes. We stand in firm opposition to this project alongside Zero Waste Ithaca and its allies and urge you to act in the best interest of the public, not corporate expansion. Sincerely, Sean Dembrosky, Sasha Kellner-Rogers, & family 1175 Ellis Hollow Road, Ithaca, NY Owner, Edible Acres Subject: Public Comment: Protecting Bird and WildlifeHabitat from Synthetic Turf at Game Farm Road Dear Members of the Town Planning Board, I am writing to express my concern regarding the planned installation of synthetic turf at multiple locations in the Game Farm Road area. Recent observations have revealed this area to be a critical habitat for various raptor species, including Red-tailed Hawks, Northern Harriers, Rough-legged Hawks, Sharp-shinned Hawks, Cooper's Hawks, and Merlins. These birds rely on the existing natural grasslands and semi-natural cover as a critical hunting ground, preying on small mammals and birds that depend on the current ecosystem. Scientific studies highlight the negative ecological impacts of artificial turf, particularly on avian diversity. Research such as Sánchez-Sotomayor et al. (2022) published in Bird Conservation International demonstrates that replacing natural grass with synthetic alternatives leads to a significant decline in bird species richness, abundance, and overall biodiversity. Although much of the research focuses on urban bird populations, the fundamental ecological principles apply to raptors as well: the loss of natural habitat and associated food sources can lead to a decline in these apex predators. Cornell University in their Supplemental Materials Submission on January 31, 2025 falsely claims on page 8 and 9 that the Game Farm Road site is not a habitat for threatened or endangered species. The following raptor species observed in the Game Farm Road area will likely be affected, of which three of them - Northern Harriers, Sharp-Shinned Hawks, and Cooker ’s Hawks - are listed as Species of Special Concern or of Greatest Conservation Need and Threatened in New York State: ● Red-tailed Hawks hunt from perches or while soaring, capturing prey such as small mammals and birds primarily on the ground. ● Northern Harriers rely on both vision and hearing to locate small mammals in open fields. This species is listed as a Species of Greatest Conservation Need and Threatened in New York State. ● Rough-legged Hawks hover and scan open terrain for rodents and other small animals. ● Sharp-shinned Hawks and Cooper's Hawks specialize in hunting small birds in semi-natural cover. Both species are classified as Species of Special Concern in New York State, meaning they are at risk of becoming threatened or endangered without continued protective measures. ● Merlins are small falcons that prey on songbirds, which rely on a healthy, biodiverse environment. Northern Harrier Sharp-Shinned Hawk Cooper ’s Hawk Furthermore, the latest agenda packet for 3/18/25 meeting revealed the Three Birds Orchid (triphora trianthophoros), a threatened species in NY, VT, ME, NH and endangered In MA, extirpated in CT, was identified as potentially inhabiting the project area. The applicant, Cornell University, asserts that the Three Birds Orchid is unlikely to inhabit the project site because it requires beech forest, which they claim is absent. However, this assertion seems an oversimplification and not entirely accurate. While the orchid thrives in moist, mature deciduous woodlands, particularly beech-maple forests, it is not strictly limited to them. The species also occurs in other deciduous forest types that provide deep leaf litter, well-drained organic-rich soils, and minimal competing vegetation. Additionally, the orchid's presence is heavily dependent on specific mycorrhizal fungi, which are not exclusive to beech forests. The applicant’s dismissal of habitat suitability based solely on the absence of beech trees fails to account for these broader ecological requirements. A comprehensive field survey including adjacent forests by an independent ecologist is necessary to determine whether the project site may, in fact, support the species rather than relying on an unverified claim. Three Birds Orchid Replacing natural grass with synthetic turf, parking paving and other developments disrupts this ecosystem by eliminating vital prey species for raptors such as rodents, insects, and small birds. The implications extend beyond these birds of prey, affecting the entire local food web. Additionally, synthetic turf and other development creates an unnatural, sterile environment that lacks the soil-dwelling organisms necessary for maintaining biodiversity. Research such as Bernat-Ponce et al. (2020) has shown that replacing semi-natural cover with artificial surfaces reduces habitat suitability and trophic resources, leading to declines in bird populations. Furthermore, Khalid et al. (2020) highlight how microplastics from artificial surfaces disrupt soil ecosystems, altering nutrient cycling and affecting plant growth, which in turn impacts insect populations that serve as prey for many bird species. (Note: Khalid et al. is conveniently dismissed as irrelevant study by Cornell University among many others in Zero Waste Ithaca’s bibliography in Cornell University’s submissions). Recent research has further demonstrated the risks that synthetic materials pose to avian species. Tokunaga et al. (2023) found polypropylene, polyethylene, and ethylene vinyl acetate microplastics in the lungs of wild birds in Japan, providing direct evidence that birds inhale airborne microplastics. These same plastics are major components of synthetic turf, yet Cornell dismisses this study as irrelevant because it does not specifically focus on synthetic turf fields. This argument ignores the well-documented shedding of synthetic fibers from artificial turf blades and other turf system components due to wear and weathering, which can lead to inhalation and ingestion by birds and other wildlife. While polypropylene, polyethylene, and EVA microplastics may come from multiple sources, synthetic turf is a known contributor to microplastic pollution through abrasion, runoff, and atmospheric dispersion. Given that raptors like Northern Harriers and Cooper ’s Hawks hunt in open fields, they are particularly vulnerable to airborne contaminants that accumulate in their hunting grounds. Dismissing this research disregards the broader implications of synthetic turf ’s environmental impact on avian species. Cornell's claim that there are "100 acres of natural space" surrounding the project site (February 21, 2025 Supplemental Materials submission, p. 8) deliberately obscures the broader context: Cornell plans to develop the entire site with additional synthetic turf fields, parking lots, and artificial structures. The current piecemeal approach to approvals allows Cornell to evade a full Generic Environmental Impact Statement (GEIS) by avoiding comprehensive scrutiny for the entire project around the site. Rather than developing all projects at once potentially causing controversy, Cornell has strategically started development away from residential areas, incrementally expanding synthetic surfaces while minimizing opposition at each phase. The synthetic turf baseball field in the middle of the area was first, and now the northernmost site on Game Farm Road is being targeted for the field hockey field. The long-term plan for additional artificial turf, increased pavement, more lighting, and increased vehicular activity will introduce noise pollution, light pollution, runoff contamination, and trash and litter accumulation, all of which negatively impact wildlife beyond the immediate site. It is also important to note that turf blades backing and shock pads are all sources of microplastic and PFAS pollution. On that note, we noticed Cornell’s submissions conveniently omitted Whitehead’s 2023 study, a full Ph.D. dissertation, which provides critical evidence of PFAS contamination in artificial turf blades, analyzing 27 samples using multiple methods. PFAS were detected in all samples, with a median concentration of 5.1 ng/g and a maximum of 41.7 ng/g, while organic fluorine measurements indicated the presence of fluorinated polymer processing aids. Cornell instead cites and misrepresents Lauria et al.’s 2022 study, whose result Whtiehead discusses in her dissertation. This is a subject for another comment, but is yet another clear example of how Cornell University selectively reads and misrepresents studies from Zero Waste Ithaca’s bibliography. The sources referenced above are just a few examples of the extensive research available in the carefully curated bibliography, which includes peer-reviewed literature on the environmental impacts of synthetic turf. The ongoing pattern of misrepresentations of the studies and our submissions is a great concern. Planning board members are strongly urged to consult the original submissions and sources in our bibliography directly before making decisions based on misrepresentations. Given the strong scientific evidence indicating the detrimental effects of synthetic turf on bird populations and broader ecosystems, we urge the Town Planning Board to reconsider this proposal and prioritize conservation-minded alternatives – a call on GEIS. Maintaining natural grass and investing in habitat preservation aligns with the broader goal of protecting biodiversity and ensuring that species such as those listed above continue to thrive in the Game Farm Road area. Thank you for your time and consideration. Sincerely, Amina Mohamed Ph.D. Candidate Ecology and Evolutionary Biology Cornell University References: Audubon Center New York. Northern Harrier (Circus cyaneus): Guidance for Conservation. Accessed March 10, 2025. https://greenelandtrust.org/wp-content/uploads/2022/03/Audubon-Northern_Harrier.pdf. This document provides conservation guidance for the Northern Harrier, which is listed as a Threatened species in New York State. It details the species' habitat preferences, hunting behavior, and nesting habits, emphasizing its reliance on open grasslands and wetland areas. The resource highlights ongoing conservation efforts and the importance of maintaining suitable environments for this raptor ’s survival. Bernat-Ponce, Edgar, José A. Gil-Delgado, and Germán M. López-Iborra. "Replacement of Semi-Natural Cover with Artificial Substrates in Urban Parks Causes a Decline of House Sparrows Passer Domesticus in Mediterranean Towns." Urban Ecosystems 23, no. 3 (2020): 471–481. https://doi.org/10.1007/s11252-020-00931-w. This study investigates the effects of urban park remodelling, specifically replacing semi-natural substrates with artificial surfaces, on the abundance of House Sparrows in Mediterranean towns. Results show that such remodelling reduces habitat suitability and trophic (nutrition or feeding) resources, leading to a significant decline in sparrow populations, emphasizing the need for urban planning measures to preserve biodiversity. Cayuga Bird Club. “Reynolds Game Farm.” Accessed March 10, 2025. https://sites.google.com/site/cbc14850/where-to-bird/reynolds-game-farm . This webpage provides an overview of the Reynolds Game Farm, highlighting its role as a habitat for various raptor species, including Red-tailed Hawks, Northern Harriers, Rough-legged Hawks, Sharp-shinned Hawks, Cooper's Hawks, and Merlins. Notably, the Northern Harrier is classified as Threatened in New York State, and both the Sharp-shinned Hawk and Cooper's Hawk are designated as Species of Special Concern. The site has historically hosted high concentrations of Red-tailed Hawks and continues to support diverse raptor populations. This source is valuable in documenting the ecological significance of the area and reinforcing concerns about the impact of synthetic turf development on protected and at-risk species. Khalid, Noreen, Muhammad Aqeel, and Ali Noman. "Microplastics Could Be a Threat to Plants in Terrestrial Systems Directly or Indirectly." Environmental Pollution 267 (December 2020): 115653. https://doi.org/10.1016/j.envpol.2020.115653.This review examines the potential threats posed by microplastics (MPs) to terrestrial ecosystems, focusing on their impacts on soil and plants. It highlights how MPs alter soil physicochemical properties, affect plant community composition, and potentially create toxicity through root uptake. The study also explores how MPs disrupt nutrient cycling and the soil's carbon-to-nitrogen ratio, emphasizing their long-term environmental risks. The authors stress the limited understanding of MPs in terrestrial systems and call for further research to address these gaps, particularly regarding their effects on ecosystem functioning and biota. New Jersey Department of Environmental Protection. "Rare Plant Profile: Triphora trianthophoros (Three Birds Orchid)." April 2022. https://www.nj.gov/dep/parksandforests/natural/heritage/docs/triphora-trianthophoros-thr ee-birds-orchid.pdf. New York State Department of Environmental Conservation. “List of Endangered, Threatened and Special Concern Fish and Wildlife Species of New York State.” Accessed March 10, 2025. https://www.dec.ny.gov/animals/7494.html. This webpage provides an official listing of endangered, threatened, and special concern species in New York State. It identifies the Northern Harrier as a Threatened species and the Sharp-shinned Hawk and Cooper ’s Hawk as Species of Special Concern. The resource is valuable for understanding the legal protections afforded to wildlife at risk and their conservation status within the state. Ramstetter, Jennifer M. Triphora trianthophora (Swartz) Rydb. (Three-birds Orchid) Conservation and Research Plan. New England Wild Flower Society, May 2001. https://newfs-society.s3.amazonaws.com/documents/Triphoratrianthophora.pdf. Sánchez-Sotomayor D, Martín-Higuera A, Gil-Delgado JA, Gálvez Á, Bernat-Ponce E. “Artificial Grass in Parks as a Potential New Threat for Urban Bird Communities.” Bird Conservation International. Cambridge University Press, July 26, 2022. https://doi.org/10.1017/s0959270922000119 This study demonstrates that replacing natural grass with artificial turf in urban parks in eastern Spain negatively impacted bird diversity. Parks with artificial grass show reduced species richness, abundance, and gamma diversity compared to parks with natural grass. These findings highlight the harmful effects of artificial turf on urban bird communities and its threat to bird conservation. Tokunaga, Yurika, Hiroshi Okochi, Yuto Tani, Yasuhiro Niida, Toshio Tachibana, Kazuo Saigawa, Kinya Katayama, Sachiko Moriguchi, Takuya Kato, and Shin-ichi Hayama. "Airborne Microplastics Detected in the Lungs of Wild Birds in Japan." Chemosphere 321 (April 2023): 138032. https://doi.org/10.1016/j.chemosphere.2023.138032. This study revealed the presence of airborne microplastics (AMPs) in the lungs of wild birds in Japan using µFTIR spectroscopy, marking the first evidence of AMP inhalation in avian species. Common polymers such as polypropylene, polyethylene, and ethylene vinyl acetate were found in the lungs, emphasizing the dual exposure risk of ingestion and inhalation for birds in polluted environments. Wang, M., Zhou, P., DuBay, S., Zhang, S., Yang, Z., Wang, Y., Zhang, J., Cao, Y., Hu, Z., He, X., Wang, S., Li, M., Fan, C., Zou, B., Zhou, C., and Wu, Y. “Assessing Microplastic and Nanoplastic Contamination in Bird Lungs: Evidence of Ecological Risks and Bioindicator Potential.” Journal of Hazardous Materials 487. April 5, 2025. https://doi.org/10.1016/j.jhazmat.2025.137274. This study provides evidence of airborne microplastic (MNP) contamination in the lungs of birds, demonstrating the pervasive nature of MNP pollution and its ecological risks. The research analyzed 51 bird species, finding microplastics in every lung sample tested, with an average of 416.22 MP particles per gram of lung tissue. The detection of both microplastics (MPs) and nanoplastics (NPs) underscores the scale of airborne plastic pollution and its potential impact on respiratory health. Larger-bodied, terrestrial, and carnivorous birds exhibited higher plastic burdens, indicating that ecological traits influence exposure levels. Whitehead, Heather D. Development of Analytical Methods for Highly Selective and Sensitive Analysis of Compounds Relevant to Human Health and the Environment. PhD diss., University of Notre Dame, 2023. https://curate.nd.edu/articles/thesis/Development_of_Analytical_Methods_for_Highly_Se lective_and_Sensitive_Analysis_of_Compounds_Relevant_to_Human_Health_and_the_ Environment/24869502?file=43760148. Dropbox full pdf backup: https://www.dropbox.com/scl/fi/73xaku3dwi0jjtgamnoe3/WhiteheadHD042023D-1.pdf?r lkey=y871tnevcqk4r0kwlzd42qhke&st=ioc6xn65&dl=0. This dissertation provides critical evidence of PFAS contamination in artificial turf blades, analyzing 27 samples using multiple methods. PFAS were detected in all samples, with a median concentration of 5.1 ng/g and a maximum of 41.7 ng/g, while organic fluorine measurements indicated the presence of fluorinated polymer processing aids. These findings confirm that PFAS are embedded in synthetic turf materials, raising concerns about long-term environmental and human exposure risks. Woelke, Dianne. Public Comment to The Town of Ithaca, NY, Planning Board. Safe Healthy Playing Fields, Inc., March 4, 2025. https://www.dropbox.com/scl/fi/aapcjpmjg2i2z0hqcalbz/Dianne-Woelke-Cornell-4-Mar-2 025.pdf?rlkey=chlldd7nj6ikchjlne2m2v5ac&st=dlwr0wk5&dl=0 This document, prepared by Safe Healthy Playing Fields, Inc., presents arguments in favor of a full environmental review for the Cornell GFR Hockey Field project. It highlights concerns regarding synthetic turf, including its environmental, health, and financial impacts. The report cites various studies on microplastic pollution, toxic runoff, and the presence of harmful chemicals in artificial turf. It also discusses legal and regulatory considerations, emphasizing the need for transparency and accountability from Cornell University. From: To: Subject: Sent: Daniel Keough Town Of Ithaca Planning; pbstaﬀ@cityoﬁthaca.org; Plastic turf projects. 3/18/2025 11:58:11 AM **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 Please require an Environmental Impact Assessment for all microplastic turf projects, including Cornell University. Why would they be allowed to bypass environmental review, for projects that clearly have an environmental impact? -- Daniel Keough From: To: Subject: Sent: Sara Hess Town Of Ithaca Planning Comments on Synthetic Turf - Require an EIS! 3/18/2025 12:21:49 PM **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 members of the Planning Board: I have looked at a lot of documentation by scientific researchers about the health hazards of Synthetic Turf and microplastics. I understand that the research studies are impossible for me, as a non-scientist, to fully comprehend. I do not expect you to be able to read or understand or evaluate these studies either. THEN, my question is this: Why do you reject the option of requiring an Environment Impact Study, specifically provided in public policy, to help with decisions with complex questions that must be answered in order to go forward with assurance to the public? An EIS is the obvious and ethical path for the Planning Board to take. Sincerely, Sara Hess 124 Westfield Dr, Ithaca, NY From: To: Subject: Sent: Margaret McCasland Town Of Ithaca Planning key points re: Cornell's artiﬁcial turf 3/18/2025 12:01:58 PM **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 While I am on record with you as opposed to any use of artificial turf for playing fields and feel strongly that you should declare the need for a GEIS, here are some key conditions that should be mandated in ENFORCEABLE ways for any plan to be seriously considered. NOT in any order: RECYCLING.Cornell should be able to show a contract for ecologically recycling the type of turf and underlayments used. Promises of an intent to recycle are meaningless is recycling is not a reasonable (and thus likely to be used) option. NATURAL GRASS: The use of herbicides, pesticides and fertilizer can be very polluting. However it doesn't have to be, and some experts at Cornell know who to use minimal chemicals safely. This should be mandatory NOW and Cornell COoperative Extension could be helping athletic and recreation departments around the state do so. WATER FILL: Spraying water onto the field as "infill" instead of crumb rubber will only increase the chance of polluting run-off. Also the water is likely to evaporate quickly during extreme heat. I know little about this method, but a GEIS would be a good way to learn more about its likely impacts. "No PFOA": Since the synthetic turf is made of flexible plastic, it contains a plasticizer (otherwise almost all plastics are brittle). There are many plasticizers out there, most (perhaps even all) of which are endocrine disruptors. Insist on knowing the exact and COMPLETE type of plastic to be used, including whether there are any forms of PFAS (umbrella term). The type being proposed may not have PFOA in it, but it likely has another problematic chemical. Thank you for your careful consideration of the many factors. Please declare the need for a GEIS. Margaret McCasland Town of Ithaca PS: Cornell should show leadership within the NCAA and work to change the regulation that women's field hockey MUST be played on synthetic turf. As a former field hockey player, I still believe in the "home field advantage" that comes from using actual grass.