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Home My WebLink AboutAll public comments 5.6.25 PB1 From:Regi Teasley <rltcayuga@gmail.com> Sent:Sunday, April 20, 2025 10:35 AM To:Town Of Ithaca Planning; dgrunder@cityofithaca.org Cc:Regi Teasley Subject:Free Online Webinar: Microplastics’ Impact on the Brain & Heart — Beyond Plastics - Working To End Single-Use Plastic Pollution **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or aƩachments. Any quesƟons please contact the IT department Good people on the Planning Boards, Since we area residents rely on your informed judgment about the safety of projects that come before you, it is incumbent upon you to be as well-informed as possible. Unlike a jury trial, where jurors are selected precisely because they know liƩle to nothing about the case before them, your task is to bring you understanding of the larger context to the project and the speciﬁc informaƟon before you. _____ This presentaƟon will undoubtedly be of use to you, and I would urge the staﬀ to view it as well. hƩps://www.beyondplasƟcs.org/events/webinar-may-2025-microplasƟcs-impact _____ As you well know, our naƟonal and global situaƟon is rapidly changing, both climate and naƟonal/internaƟonal relaƟons. In order to be eﬀecƟve, our boards and support staﬀ must join together to become learning organizaƟons. Otherwise, we are always at square one and that is a recipe for failure. Thank you for reading my comments and thinking about them. Sincerely, Regi Teasley Ithaca, NY ___________ Protect what is leŌ, recover what is lost of the fair earth. William Morris, “Art and the Beauty of the Earth.” 1881 From: To: Cc: Subject: Aachments: Sent: Chris Balestra Town Of Ithaca Clerks Department; CJ Randall; Nick Quilty-Koval; zfaraj@cornellsun.com; Abby Homer; RE: Aending Town Board Meeng PB Agenda 2025-04-15.pdf 4/28/2025 10:50:29 AM Hello Zeinab, Thank you for your connued interest in the Cornell Game Farm Road Field Hockey ﬁeld project. We aren’t sure if you were asking a queson or making a statement about the NYS 2026 Carpet Law in your email. Do you have a speciﬁc queson? The New York State Carpet Collecon Program Law, Arcle 27, Title 33 of the Environmental Conservaon Law, went into eﬀect on December 28th, 2024. NYS Department of Environmental Conservaon is holding a Pre-Rulemaking Stakeholder Meeng on Wednesday, June 11th, 2025; more informaon and a link to register to aend is at hps://dec.ny.gov/environmental-protecon/recycling-composng/carpet. We will forward your comment to the Planning Board, regardless. The Board will meet next on May 6, 2025. Aached is the agenda and public hearing noce for the meeng, which includes a Zoom link should you choose to aend the meeng via Zoom. Cheers, Chris Chrisne Balestra, Senior Planner Town of Ithaca Planning Department 215 North Tioga Street Ithaca, NY 14850 Ph: 607-273-1721, ext. 121 Cell: 607-227-0956 Email: cbalestra@townithacany.gov From: Zeinab Faraj <zfaraj@cornellsun.com> Sent: Saturday, April 26, 2025 8:58 PM To: Town Of Ithaca Clerks Department <clerks@townithacany.gov> Subject: Re: Aending Town Board Meeng Good evening Town of Ithaca Planning Board I hope you are doing well, Thank you so much for allowing me to attend meetings and speak to you all about this project. I had a question about the relevance of the 2026 NYS Carpet law in this project? Best, Zeinab Faraj On Tue, Mar 18, 2025 at 11:48 AM Town Of Ithaca Clerks Department <clerks@townithacany.gov> wrote: Good Morning Ms. Faraj, I am the Town Clerk who manages the ZOOM program during the meeting. I am confused and would really like to understand how you were “barred” from the meeting. Feel free to call me at 607-273-1721 opt 1 or if you could answer these questions, maybe I could figure it out. Are we talking about the Planning Board meeting on March 3rd that began at 6:30pm and ended at about 10pm and we did take a 10 minute break around 9pm? At what time did you try to attend? How did you try to attend the meeting? In person? Via Zoom? How and who told the meeting was over? One possibility is the persons to be heard was held at the beginning of the meeting. Because there was no Public Hearing associated with the agenda item concerning the Game Farm Road project, people who wanted to comment did so under Persons to be Heard. IF someone from the public left the meeting after speaking or after the Persons to be Heard agenda item was closed, someone from the public could have meant that part of the meeting, or the opportunity to speak, was over. As Abby said, all our meetings of all boards and committees are open to the public and most are held here at Town Hall where the public can attend in person. Four of our meetings are held hybrid, meaning in person and via ZOOM for the public to participate either way, during agenda items that are either Persons to be Heard, or Public Hearings. Thank you in advance for any clarification you can provide, Paulette Paulette Rosa Town Clerk Town of Ithaca 215 North Tioga Street Ithaca, New York 14850 607-273-1721, ext. 110 Website: https://townithacany.gov/ From: Abby Homer <ahomer@townithacany.gov> Sent: Tuesday, March 18, 2025 9:35 AM To: zfaraj@cornellsun.com Cc: Caitlin Cameron <cameron.caitlin@gmail.com>; Chris Balestra <CBalestra@townithacany.gov>; CJ Randall <cjrandall@townithacany.gov>; Town Of Ithaca Clerks Department <clerks@townithacany.gov> Subject: FW: Aending Town Board Meeng Hi Zeinab, I am sorry that you were misguided at the last meeting. All meetings are open to the public in person and on Zoom. To just watch and not comment, there is also YouTube. Planning Board tonight starts at 6:30 and the agenda is attached. I have CC’d the Clerks office here also so they know you will be there in person. Thanks for reaching out! Abby From: Zeinab Faraj <zfaraj@cornellsun.com> Sent: Monday, March 17, 2025 11:11 AM To: Abby Homer <ahomer@townithacany.gov> Subject: Aending Town Board Meeng **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 Mrs. Homer I hope you are doing well. My name is Zeinab Faraj, a reporter for the Cornell Daily Sun. I wanted to ask you if I could please attend this week’s town board meeting. I would love to hear people’s thoughts on the Game Farm Field situation and this meeting will provide me invaluable insights on the situation. I am explicitly asking for your permission because two weeks ago, I wanted to attend the meeting but was barred from doing so by a lady who told me the meeting was already over. Although I was able to attend on Zoom, I would like to request to be allowed to attend in person to improve my experience. Thank you for your time and understanding. Best, Zeinab Faraj 1 From:Joseph Wilson <wilson.joe79@gmail.com> Sent:Saturday, May 3, 2025 10:32 PM To:Town Of Ithaca Planning Subject:Anticipated Site Plan Approval of Game Farm Site Artificial Turf Fields Follow Up Flag:Follow up Flag Status:Flagged **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or attachments. Any questions please contact the IT department To the Town of Ithaca Planning Board Members, I am Joe Wilson. I have appeared before you in the past. I am a retired lawyer. I recently completed 9 years of service on a nearby Town's planning board. By training, observation and practice, I am familiar with standard practices among the several planning boards in the area. I have followed your approval process for the Game Farm field installation. I am aware of the well-established health and safety consequences of the installation and use of artificial turf fields such as those proposed. Consistent with what I understand to be standard planning board practice, I urge you to make your site plan approval specifically conditioned on the implementation of the several commitments by Cornell to ensure the health, safety and welfare of those of us likely to be impacted by the installation and use of the artificial turf fields at the Game Farm site. -- Joseph M. Wilson 75 Hunt Hill Road Ithaca NY 14850 2 Landline: 607-539-1159 From: To: Subject: Sent: Anne Rhodes Town Of Ithaca Planning arﬁcial turf 5/5/2025 11:41:11 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 Town of Ithaca Planning Board: I am a resident of Tompkins County, and am seriously concerned about how we are locally continuing to pollute our planet. Plastic turf fields are polluting, dangerous, and unnecessary. As you consider approving the site plan for the artificial turf field at Game Farm on Ellis Hollow Road, many of us in the community urge you to make approval conditional on the implementation of Cornell’s commitments to take measures that will minimize adverse effects on the environment and protect the health, welfare, and safety of all who use the facilities. What will guarantee that Cornell even follows through with their promises? Please do everything in your power to ensure that the University will follow through with these commitments over the life of the projects, up to and including their eventual disposal. It's clear that Cornell is ignoring our concerns, and we are afraid that you, as a Board, are also ignoring them. We are disappointed in the NEG DEC, and hope that at least, you can hold Cornell accountable in the future. Many of the problems will intensify as the plastic ages. Just because Cornell is large and rich, it should not be able to ignore the science and community concerns. I know we cannot sue, as we don't have "standing," but this is our little piece of the earth and we are trying our best to protect it. Please do the right thing. Sincerely, Anne Rhodes -- "Looking at life from a different perspective makes you realize that it's not the deer that is crossing the road, rather it's the road that is crossing the forest." - Mohammad Ali Brian Eden Comment on the Proposed Site Plan Approval for the Cornell Game Farm Road Facility Project May 5, 2025 Dear Planning Board Members, I was very disappointed in the lack of rigor applied to the complex issues raised by the public during this project’s environmental review. Several commenters had subject matter expertise that received little consideration from Planning Board members. I wish to reflect on these issues briefly prior to advocating for some measures that might address the review ’s shortcomings. There is nothing to be done about the excess greenhouse gas emissions that will result from the plastics produced for this project. Albeit relatively small in quantity many such poor decisions aggregated from unrelated projects will contribute to the acceleration of the existential climate threat. The present atmospheric concentration of CO2 is the highest in 14 million years (https://phys.org/news/2023-12-current-carbon-dioxide-million-years.html). In a recently peer-reviewed paper, published in the journal Earth System Dynamics, humankind is at risk of triggering various climate "tipping points" absent urgent action to dramatically reduce planet-heating emissions from fossil fuels. Once these tipping points are achieved, there will be little likelihood that a catastrophic impact on civil society may be avoided In recent years, forever chemicals have been increasingly recognized as one of the most significant environmental threats of our time. They persist in the environment for millenniums. They spread rapidly through air and water, polluting ecosystems and human bodies everywhere, and there they stay, with the potential to damage cells and alter our DNA. PFAS, the best studied of these chemicals, has been linked to obesity, infertility, testicular cancer, thyroid disease, immune suppression and life-threatening pregnancy complications, among other maladies. But unlike the daunting environmental threat, climate change, forever chemicals have spawned a forceful bipartisan response, driven by a network of unlikely activists. Across the country, thousands of ordinary Americans whose lives have been upended by PFAS — firefighters, farmers, factory workers, veterans and suburban moms — are fighting to turn off the tap on these chemicals. Their efforts, which often differ from those of conventional environmental groups, have helped ignite a chain reaction that has led to numerous congressional hearings and hundreds of bipartisan bills in Washington and statehouses, as well as federal regulations. The Environmental Protection Agency has set near-zero caps on several PFAS in drinking water (https://www.nytimes.com/2025/04/27/opinion/forever-chemicals-pfas- pfoa.html?smid=nytcore-ios- share&referringSource=articleShare&sgrp=c&pvid=8F315D89-1F71-4E1E-948E- F715275B6EAF). Unfortunately, it appears that we have not yet achieved such consensus on the seriousness of this threat locally and there are few here that apparently support the precautionary principle. None of the above was considered a significant impact in the Planning Board’s determination. Had these issues been discussed in more detail and had the Planning Board availed itself of third-party independent support via an environmental impact study, there might have been a substantive outcome that the community could have embraced. At the March 18 meeting approximately 15 residents spoke in opposition to various aspects of the project. Soon thereafter, without discussing any of the comments, the Board voted unanimously to Neg Dec the project. The need for an EIS for a Town project is infrequent, yet the Planning Board will apparently never utilize this valuable tool even when the subject matter under review may be beyond the members personal expertise. Do not members wish to encourage the community to view their decisions as legitimate? Should the NCAA facility requirements for field hockey be prioritized over public health and environmental considerations. Often commitments during the environmental review process are regarded by applicants as little more than public relations gestures. Once a project is under construction, the promises may be quickly forgotten by al involved unless memorialized. The community residents are requesting that the Planning Board make the commitments regarding PFAS-free turf, the proposed filtration system, and the recycling plan be made conditional and enforceable in the Site Plan Approval. As the former Chair of HeatSmart Tompkins, having experienced significant positive interaction with the Town’s Code Enforcement staff, I have strong faith in their ability to supervise conditions included with the Final Site Plan Approval. The area of the artificial turf field will never be a greenfield again, but if we remain focused on our public health and environmental policy objectives, we may mitigate some of the potential damage. Please support the reasonable requests from the community’s residents. 1 From:Regi Teasley <rltcayuga@gmail.com> Sent:Sunday, May 4, 2025 5:48 PM To:Town Of Ithaca Planning Subject:Re: Hearing residents about Review of Cornell Playing Fields Project Follow Up Flag:Follow up Flag Status:Flagged **WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or aƩachments. Any quesƟons please contact the IT department Members of the Town of Ithaca Planning Board,, I have lived in Ithaca for 40 years. This is my home. I am urging you to reassess your process and acƟvely listen to, and center, informed residents and taxpayers in your decisions. As a reƟred Sociologist, I am familiar with organizaƟonal structure, funcƟon and dysfuncƟon. As you may know, organizaƟons have formal and informal cultures that powerfully impact human behavior. As well, small group dynamics factor into the acƟons of their members. They can come to feel there are in-groups and out-groups. The recent process of the Town of Ithaca Planning Board has been very concerning to me. Over the past several months I have submiƩed wriƩen comments and made oral comments pertaining to proposed arƟﬁcial turf ﬁelds at Cornell University. I have carefully followed the meeƟngs. Unfortunately, throughout this period, the board appeared to be group of people that was as concerned with internal harmony as with their board obligaƟons. Some of you seem unable to see the impact of board decisions. I saw liƩle interest in learning from experience and prior decisions taken. A learning organizaƟon involves quesƟoning process and seeking to beƩer understand maƩers of importance. We can all improve our work. I fear that most members lack full understanding of ecosystems, watersheds, water quality issues, and public health issues, and may be unfamiliar with evaluaƟng scienƟﬁc research. Instead, it appeared that you relied on the promises of Cornell representaƟves. Were you unduly inﬂuenced by Cornell representaƟves and advocates for the playing ﬁelds? Were you the neutral and discerning body that we residents need you to be? I deeply care about the viability of our area, a parƟcularly valuable region in a period of climate crisis. Do you? I wonder if you can fulﬁll your mission to protect our community from unnecessary risks. But now you have an opportunity to reassess process, receive relevant training and truly serve the community. The future we face is problemaƟc, to say the least, can we rely on you to step up to the challenge? Sincerely, Regi Teasley, Ph.D. 2 Ithaca, NY ___________ Protect what is leŌ, recover what is lost of the fair earth. William Morris, “Art and the Beauty of the Earth.” 1881 1 From:Elmer Ellis Ewing <eee1@cornell.edu> Sent:Sunday, May 4, 2025 9:20 PM To:Town Of Ithaca Planning Subject:Cornell Game Farm field artificial turn approval Follow Up Flag:Follow up Flag Status:Flagged **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 Town of Ithaca Planning Board: I am an emeritus professor at Cornell, but I write as a citizen of the Town of Ithaca to express personal concerns. As you consider approving the site plan for the artiﬁcial turf ﬁeld at Game Farm on Ellis Hollow Road, my wife and I urge you to make approval conditional on the implementation of Cornell’s commitments to take measures that will minimize adverse eƯects on the environment and protect the health, welfare, and safety of all who use the facilities. We also ask you to do everything in your power to ensure that the University will follow through with these commitments over the life of the projects, up to and including their eventual disposal. We say this because we are aware of how the many issues faced by busy administrators can lead them to overlook such promises as time passes, whereas many of the problems will intensify as the plastic ages. Elmer and Marilyn Ewing 1520 Slaterville Road Ithaca, NY 14850 1 From:Stephen Daly <sdaly@citizenenvironmental.com> Sent:Monday, May 5, 2025 10:11 AM To:Town Of Ithaca Planning Subject:Written Comment - Cornell University Game Farm Road Project Attachments:Letter from Daly (IRAFE) to Planning Board - 5-2-25.pdf; Attachment - PFAS-in-turf- Test-methods-July 2024.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 of Ithaca Planning Board: please see the attached written comment letter with attachment regarding the Cornell University Game Farm Road Project, which I am submitting on behalf of Ithaca Residents Acting for the Environment. Please kindly conﬁrm receipt of the letter and attachment, and please also conﬁrm that this submission will be distributed to the members of the Planning Board before the public hearing scheduled the evening of May 6, 2025. Thank you, Steve Stephen D. Daly, Esq. Citizen Environmental Law PLLC 6 N Main St. Ste. 200-J Fairport, NY 14450 sdaly@citizenenvironmental.com (585) 206-1220 (office) (585) 305-1945 (cell) www.citizenenvironmental.com Municipalities and institutions often face questions regarding the presence of PFAS in artificial turf as they make decisions about play surfacing. This document is designed to provide information for municipalities, schools, community members and others about key concepts and considerations for obtaining and understanding laboratory tests. It builds upon and updates an earlier fact sheet, “Per- and Polyfluoroalkyl Substances (PFAS) in Artificial Turf Carpet” (2020).2 PFAS Vocabulary and Definitions PFAS are a category of organic chemicals that contain fluorine atoms bonded to carbon atoms. There are many PFAS chemicals – the US EPA Comptox database identifies nearly 15,000 PFAS chemicals.3–5 Definitions. A variety of definitions of the term PFAS have been developed by state, federal and other entities. Some definitions have been updated over time to reflect a new understanding of the science of PFAS, or to reflect policy priorities. The definition published by the Organization for Economic Cooperation and Development (OECD) is useful as a current, authoritative, and practical definition: “PFASs are defined as fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom (without any H/Cl/Br/I atom attached to it), i.e. with a few noted exceptions, any chemical with at least a perfluorinated methyl group (– CF3) or a perfluorinated methylene group (–CF2–) is a PFAS.”5 In some situations, a definition is provided for “regulated PFAS.” For example, one California regulation on PFAS in certain products provides a test method and a detection limit within its definition of regulated PFAS.6 This approach allows for implementation without the need to determine chemical structure of each compound. Nomenclature. Detailed information on PFAS nomenclature is available in the Interstate Technology and Regulatory Council (ITRC) fact sheet, "Naming Conventions and Physical and Chemical Properties of Per- and Polyfluoroalkyl Substances (PFAS)." Chemicals classified as PFAS include polymers and non- polymers.7 Terminology that can arise in discussions of non-polymer PFAS include distinctions between “long chain” and “short chain” PFAS, and distinctions between “linear” and “branched” PFAS.8 Certain PFAS are referred to as “precursors.” As described by ITRC, “Polyfluoroalkyl PFAS that degrade to create PFAAs [Perfluoroalkyl acids] are referred to as ‘precursors.’” PFAAs “are some of the least complex PFAS and currently are the class of PFAS most commonly tested for in the environment.”8 Certain laboratory tests focus specifically on precursors, as described below. Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Test Methods July 2024 PFAS in Artificial Turf: Test Methods 2 Sources of PFAS in artificial turf PFAS can be used in molding and extrusion of plastic products, including artificial turf.9,10 One function of PFAS is to prevent the polymer from sticking to manufacturing equipment. As explained by Dr. Heather Whitehead, “Specific uses of PFAS in the production of plastic and rubbers includes the application of polymeric fluorinated polymer processing aids as extrusion agents, non- polymeric PFAS as mold release agents for plastics and resins, and the direct production of fluoropolymer plastics and rubbers.”11,12 Fluorinated polymer processing aids (fPPAs) are polymers that are used “in the molding and extrusion of various grades of plastic.” They may be “added directly to raw plastic resins,” before the mixture is “heated, mixed and extruded or blown into a final plastic product.”11 Some PFAS processing additives on the market specify artificial grass as an intended use.10,11,13 In this case, PFAS is added to the artificial grass polymer mixture before it is passed through an extruder. An extruder is manufacturing equipment that melts and forms the polymer mixture into its desired shape. As explained by the New Jersey Department of Environmental Protection, information is available from patent literature and other sources on the potential use of fluorinated materials as processing aids, coating treatments, binding matrices, and flame retardants in artificial turf. NJ DEP notes, “Since PFAS are included in the chemical makeup of fluoropolymers that are added as polymer processing aids to improve plastic extrusion, there is also the potential of leaving a low-level fluoropolymer residual on the product following processing.”9 Health and Environmental Concerns Most PFAS chemicals break down into a common set of degradation products. These degradation products are highly persistent in the environment; they do not break down under normal environmental conditions. Some can remain in the environment for hundreds of years. As a result, introducing them into the environment has long-lasting consequences. In addition, PFAS pose bioaccumulation concerns.14–21 The human health effects of certain PFAS have been studied in depth due to widespread contamination of drinking water in some areas of the US, and from studies of health effects in fluorocarbon workers. Other PFAS have been studied in laboratory animals. Health effects documented for some PFAS include increased risk of some cancers, including kidney, testicular, and prostate cancers; effects on the endocrine system, including liver and thyroid; metabolic effects such as increased cholesterol or risk of obesity; developmental effects or delays in children; reproductive effects such as decreased fertility and complications in pregnancy; neurotoxicity; and immunotoxicity, including reduced vaccine response.22–24 Studies of polymeric PFAS also indicate that some can break down into smaller, potentially more reactive molecules in the environment.7 PFAS have been studied by many governmental and intergovernmental entities, including the Organization for Economic Cooperation and Development (OECD), the US Environmental Protection Agency (US EPA), PFAS in Artificial Turf: Test Methods 3 and the European Chemicals Agency (ECHA). Researchers have emphasized the need to address PFAS as a group rather than one by one.18,20,25 PFAS Testing: Units of Measurement and Detection Limits PFAS testing includes a variety of methods and approaches. Understanding the range of PFAS testing options can be complex because of the large number of individual chemicals in the class with varying carbon chain lengths and functional groups, and the evidence of adverse effects at very low concentrations. The choice of test method also must take account of the types of materials being tested. The following sections summarize some of the key terminology and considerations that are relevant when choosing testing methods and interpreting results. Units of Measurement Because of the hazards of PFAS at very low concentrations, the presence of PFAS in drinking water is generally measured in parts per trillion (ppt). PFAS information may also be shown in parts per billion (ppb) or parts per million (ppm), which are larger units of measurement. One ppm is a million times larger than one ppt: 1 ppm = 1,000 ppb = 1,000,000 ppt. As explained in an EPA publication, another way to understand these units is by “equating ppm to ‘one drop in one million gallons,’ ppb to ‘one drop in one billion gallons,’ [and] ‘ppt to one drop in one trillion gallons.’”26 Analytical laboratories may use a variety of units to report concentrations of PFAS. For example, one lab may present results as nanograms per liter (ng/L), while another may present the same information in ppt. These units represent the same concentration. Below are several examples of unit conversion for water and solid materials.26,27 Detection Limits When ordering PFAS analyses or interpreting results, it is important to understand detection limits. If the detection limit is too high, useful information may be missed. When ordering a test or reading test results, check the detection limit to see if it corresponds to the information you need. For example, if you need Examples of Unit Conversions Parts per million (ppm) = microgram per gram (µg/g); milligram per kilogram (mg/Kg); milligram per liter (mg/L); nanogram per microliter (ng/µL) Parts per billion (ppb) = microgram per kilogram (µg/Kg); nanogram per gram (ng/g); microgram per liter (µg/L) Parts per trillion (ppt) = nanogram per kilogram (ng/Kg/); nanogram per L (ng/L) PFAS in Artificial Turf: Test Methods 4 information on substances that may be present at the ppb or ppt level, be sure that these levels are captured in the testing. It can also be important to know that in some cases, a laboratory can determine that a chemical is present, but cannot accurately quantify the concentration that is present. A variety of terms are used to describe detection and quantitation limits. For example, EPA Method 1633 defines a “method detection limit” and a “limit of quantitation.”28 Commercial laboratories may distinguish between “method detection limit” and “reporting limit.” Academic laboratories may distinguish between “instrument detection limit” and “method detection limit.”29 And the Department of Defense distinguishes among “detection limit,” “limit of detection,” and “limit of quantitation.”30 Regardless of the vocabulary used, it is important to check definitions and to ensure that the limits of the test conducted are appropriate for the decision-making needs of those using the test results. Results may have laboratory-added “flags” or qualifiers that provide additional information. For example, a letter may be used to indicate that the substance is present but cannot be quantified accurately. Vocabulary and acronyms used in lab reports can differ among laboratories, so it is important to read the definitions in each report. PFAS Testing: Methods There are multiple factors to consider when choosing appropriate PFAS testing methods and interpreting results.31 The US EPA has developed methods for measuring PFAS for regulatory and monitoring purposes for measuring PFAS in water, soil, sediment, biosolids, and fish tissue.32 The international standards development organizations American Society for Testing and Materials (ASTM) and International Organization for Standardization (ISO) have also developed methods for measuring PFAS.33 However, there are currently no consistent guidelines for testing PFAS in synthetic materials, such as plastic and rubber. Some laboratories use modified versions of US EPA testing methods to measure PFAS in certain synthetic materials. There are various approaches for targeted testing of individual PFAS compounds in samples. However, these methods only provide information on a limited number of compounds and for specific sample types. In many cases, testing is limited to a small group of non-polymeric PFAS that have been a particular focus of regulatory activity. For example, US EPA has published methods for testing between 18 and 40 types of PFAS depending on the method and sample type (see the summary of EPA methods in Table 1).32 Lack of detection of these individual chemicals does not indicate that all PFAS are absent. Other methods have been developed to understand the presence or concentrations of all PFAS in a sample, such as methods for measuring the presence of fluorine-containing organic (carbon-containing) compounds without identifying specific chemicals. These are discussed in greater detail below. Sample preparation/extraction. It is helpful to review the laboratory’s approach, including choice of extraction solvent, to understand whether the resulting data will answer the questions that the organization wants to prioritize. For example, a test that estimates PFAS leaching into rainwater will not necessarily be sufficient to answer questions about PFAS presence and concentration in the material. It is PFAS in Artificial Turf: Test Methods 5 important for a laboratory to use appropriate methods, including an appropriate extraction solvent, to answer the questions at hand. When understanding how PFAS may leach from materials into rainwater, the US EPA recommends using an appropriate extraction fluid that is relevant to regional environmental conditions, such as rain acidity.34 Choice of laboratory. In general, organizations ordering a PFAS test should use an analytical laboratory that has experience analyzing PFAS in plastic materials. The choice of a laboratory to work with may depend on the goals of a testing effort. For example, academic laboratories can use innovative methods, while certified commercial laboratories can provide data that may be used in legal or regulatory settings. Targeted PFAS analysis Targeted chemical analyses are methods used to gather information about a specific, targeted list of chemicals.32 Existing targeted analyses for PFAS only measure a small number of the nearly 15,000 PFAS that exist. EPA initially developed standard targeted methods for measuring a small number of PFAS in drinking water and wastewater, with a primary focus on regulatory activity.32 Some labs modified these methods to measure additional PFAS and to test other media, such as solids. In January 2024, EPA developed Method 1633, which can measure at least 40 PFAS compounds in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and tissue samples. Table 1 presents a summary of EPA’s targeted PFAS testing methods. Note that the table describes only EPA methods. Other methods also exist; for example, some laboratories may use methods from ASTM or ISO. Certain methods may be quicker and lower cost than others, but may be less rigorous and have higher detection limits.35 Thus, it is essential to discuss the goals for the sample analysis with the laboratory in order to choose an analysis method and detection limits that will result in data usable for decision-making. Non-Targeted PFAS Analysis Non-targeted chemical analyses are methods used to gather information about a wide range of chemicals that may be present. Unlike targeted analyses, non-targeted analyses do not 'look for' specific chemicals, but attempt to identify all chemical signals in the data. These methods can be used to investigate the presence of PFAS that cannot be measured using other chemical-specific methods. These methods include use of high resolution mass spectrometry that can identify known and unknown analytes in a sample.32 Once chemicals have been identified using a non-targeted analysis, additional analyses can be used to measure or estimate the quantity. PFAS in Artificial Turf: Test Methods 6 Table 1. Summary of EPA’s standard targeted analytical methods for measuring PFAS. Method Description Method 537.1 (published 2018/2020; replaced method 537 published in 2009) • Measures 18 PFAS in drinking water Method 533 (published 2019) • Measures 25 PFAS in drinking water Method 8327 (published 2019) • Measures 24 PFAS in non-drinking water, including groundwater, surface water, and wastewater Method 1633 (published 2024) • Measures 40 PFAS in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and tissue. This method encompasses chemicals covered in the earlier methods. Other Test Method-45 • Measures 50 PFAS in air emissions from stationary sources, with a focus on semi-volatile and particulate-bound PFAS Other Test Method-50 • Measures 30 PFAS in air emissions from stationary sources, with a focus on certain volatile PFAS Note that this table shows only targeted methods. Sources: US EPA. 2024. “PFAS Analytical Methods Development and Sampling Research.” https://www.epa.gov/water-research/pfas-analytical-methods-development-and-sampling- research ; US EPA. 2024. “Method 1633: Analysis of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS.” https://www.epa.gov/system/files/documents/2024-01/method-1633- final-for-web-posting.pdf Total Fluorine Analysis Total fluorine (TF) analyses do not measure or identify individual PFAS compounds. Rather, TF is a measurement of fluorine atoms, in both organic and inorganic forms, without identifying specific compounds. This kind of test can be a useful first step to determining the likelihood of the presence of PFAS in a sample.31 These measurements can be performed on aqueous or solid samples and are generally more affordable than other PFAS analysis methods.36 TF can be measured using particle-induced gamma ray emission (PIGE) spectroscopy, and other techniques such as combustion ion chromatography (CIC) and combustion with an ion-selective electrode. Total fluorine analyses may also be modified to avoid detecting fluoride, which is fluorine in an inorganic form.a a If this is important, the sample must either undergo extraction into a solvent or adsorption onto a medium that will not collect inorganic fluorine or be analyzed directly for inorganic fluoride before measuring total fluorine. PFAS in Artificial Turf: Test Methods 7 Organic Fluorine Analysis PFAS are organic (carbon-containing) chemicals. Organic fluorine analyses consider the organic form of fluorine – that is, fluorine that is bonded to carbon. Fluorine can also exist in inorganic (non-carbon- bonded) forms. Inorganic forms of fluorine are not PFAS. Organic fluorine analyses can capture a broader range of PFAS compounds than targeted analyses, because they show the presence or absence of a group of chemicals, rather than measuring individual chemicals. EPA and other researchers are investigating whether measuring organic fluorine can be used as a chemical class-based analytical method for PFAS.37,38 To obtain information about total organic fluorine, it is possible to determine total fluorine and then subtract the inorganic portion. Other types of organic fluorine analyses include extractable and adsorbable organic fluorine analyses. As described by EPA, “the most common sources of organofluorines are PFAS and non-PFAS compounds such as pesticides and pharmaceuticals.”39 Some pharmaceuticals and pesticides contain or are considered PFAS.40,41 The vocabulary used to describe these compounds depends in part on the choice of definition of the term PFAS. Total organic fluorine. To account for the possible presence of fluoride (an inorganic form of fluorine) in a sample, some labs can test a sample for both fluoride and total fluorine. If fluoride is not detected, it is usually reasonable to conclude that all of the fluorine in the sample is organic fluorine. If fluoride is detected, it can be quantified and subtracted from the total fluorine for an estimation of total organic fluorine.b Extractable and adsorbable organic fluorine analyses. Extractable organic fluorine (EOF) tests measure only organic fluorine by removing the inorganic fraction of fluorine through extraction.38 Following extraction, fluorine can be measured using CIC. Extractable organic fluorine analyses are limited to compounds that can be extracted using the chosen extraction method. In 2024, EPA published a method for measuring adsorbable organic fluorine (AOF, Method 1621) in aqueous matrices. This method uses granular activated carbon to adsorb fluorinated compounds, and its utility can vary depending on the chain length of the fluorinated compounds in the sample.42 Total Oxidizable Precursor Assay A Total Oxidizable Precursor (TOP) Assay allows researchers to indirectly assess the presence of a wide range of PFAS, many of which are missed by targeted methods. This method mimics environmental degradation by oxidizing a sample, allowing “precursors” to degrade into perfluoroalkyl acids (PFAAs).9 One portion of a sample is analyzed for PFAS and a second portion is oxidized and then analyzed for PFAS. The difference between the pre-oxidation PFAS content and the post- oxidation PFAS content is an estimate of the amount of precursors in the sample. b Gillian Miller of Ecology Center has noted that this approach comes with a caveat that certain materials, particularly geological particles (rocks), are not suitable for total fluorine testing via combustion or inorganic fluoride testing via ion- selective electrode. Erroneous results may occur, for example, from fertilizer containing phosphate rock. PFAS in Artificial Turf: Test Methods 8 TOP assay enables researchers to detect the presence of precursors, even if they do not know which specific precursors are present.43 Interpreting Test Results Interpreting and comparing testing results across sites and sample types can be challenging due to variations in methods used for analysis, units and reporting protocols, quality control criteria, and data review procedures across labs.44 The level of detail needed for interpretation and assessment of data quality depend on the goals of testing. A pilot or general screening study may need less detail than that needed for enforcement actions or comparison to regulatory standards, for example. When interpreting laboratory test results, it is important to understand which tests were conducted and what those tests can detect. For example, if an organization is interested in determining whether fluoropolymers are present in the product, an appropriate test must be selected. Typical methods for targeted PFAS or for extractable organic fluorine will not detect fluoropolymers, while total fluorine will detect them (although not identify them). Therefore, a total fluorine test is an important step to detect the presence of fluoropolymers. It is also important to understand that the lack of detection of one or more specific PFAS does not indicate that a material is free of PFAS. For example, if a sample is tested for 40 PFAS compounds (“target” list), and none were detected, this means the sample did not contain those 40 compounds at the detection limit used for each compound. One cannot conclude that no PFAS of any kind were present. It is possible the sample contained compounds not on the target list, or contained levels of the targeted compounds below the detection limit. A total fluorine test, an organic fluorine test, or a TOP assay can be helpful in determining whether PFAS may be present in a sample. When conducting targeted testing, it may also be useful to consider which chemicals are most likely to be present. For example, in some cases, some PFAS compounds may be more likely to be found in older products, and others may be more likely to be present in newer products, unless the new product also contains older, repurposed or recycled components. Sometimes reports on laboratory tests may also include text about risk. Risk assessment is an approach to estimating possible health effects of exposure to one or more toxic chemicals. It is distinct from identifying or quantifying chemicals in products. Risk assessment relies on a variety of additional assumptions and calculations related to exposure and other factors. Results of a risk assessment can vary widely based on the assumptions that are used. Table 2 briefly summarizes the approaches discussed in this document. The terminology used to describe and categorize approaches to testing PFAS can vary among sources, and there are other ways to categorize these types of tests. For example, some sources may categorize tests based on whether they are quantitative or qualitative. Regardless of the terminology used, it is essential to understand the scope and limitations of any tests that are used in decision-making. PFAS in Artificial Turf: Test Methods 9 Table 2. Summary of testing options and relevance for decision-making about artificial turf products Type of test Function of test Utility of test Targeted PFAS analysis • Identifies and quantifies a specific list of compounds. • Useful for discussions related to regulatory standards for environmental contamination. Non-targeted PFAS analysis • Attempts to identify all PFAS compounds that are present, without quantifying them. • Useful if there is a need to identify exactly which PFAS compounds are present. Total fluorine analysis • Measures fluorine atoms, without identifying specific compounds. • Useful as a first step in determining whether a product may contain PFAS. Less specific than an organic fluorine analysis, as inorganic fluorine is also captured by this approach. • Includes quantitative information. Organic fluorine analysis • Measures organic fluorine atoms, without identifying specific compounds. • Useful in determining whether a product may contain PFAS. • Includes quantitative information. Total oxidizable precursor (TOP) assay • Provides information on the quantity of precursors that degrade into PFAAs. • Useful in determining whether a product contains certain PFAS. • Encompasses more compounds than a targeted PFAS analysis, but fewer compounds than an organic fluorine analysis. Note: The terminology used to describe and categorize approaches to testing PFAS can vary among sources; this table provides one approach. Regardless of the terminology used, it is essential to understand the scope and limitations of any tests that are employed. Acknowledgments This report was prepared by Lindsey Pollard, MS and Rachel Massey, ScD (Lowell Center for Sustainable Production), with contributions from Gillian Miller, PhD (Ecology Center). Comments on drafts of this document were provided by Susan Chapnick, MS; Wendy Heiger-Bernays, PhD; Nancy Rothman, PhD; and Zhenyu Tian, PhD. This document 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 Goodow’s Technical Memorandum on PFAS in Artificial Turf, Department of Environmental Protection, State of New Jersey. Research for this report and for the 2020 fact sheet 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, PFAS in Artificial Turf: Test Methods 10 and government agencies to build healthy work environments, thriving communities, and viable businesses that support a more sustainable world. References 1. 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). 2. Toxics Use Reduction Institute (TURI). Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf Carpet, https://www.turi.org/TURI_Publications/TURI_Chemical_Fact_Sheets/PFAS_in_Artificial_Turf_Carpet?fbclid=IwAR0 DfBbF5E-f_ZwcdH7YGkhIeugP_gMxPBuS6cxnABvWQpngF9SuQoJdN04, (2020). 3. Organization for Economic Cooperation and Development. Toward a new comprehensive global database of per- and polyfluoroalkyl substances (PFASs): summary report on updating the OECD 2007 list of per-and polyfluoroalkyl substances (PFASs). ENV/JM/MONO(2018)7. Series on Risk Management No. 39, http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV-JM- MONO(2018)7&doclanguage=en (2018). 4. US EPA. PFAS structures in DSSTox (update August 2022). CompTox Chemicals Dashboard v2.4.0, https://comptox.epa.gov/dashboard/chemical-lists/PFASSTRUCTV5 (2024, accessed 19 April 2024). 5. Organisation for Economic Co-operation and Development (OECD). Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations and Practical Guidance. Series on Risk Management No. 61, https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/terminology-per-and-polyfluoroalkyl- substances.pdf (2021). 6. 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). 7. Lohmann R, Letcher RJ. The universe of fluorinated polymers and polymeric substances and potential environmental impacts and concerns. Curr Opin Green Sustain Chem 2023; 41: 100795. 8. Interstate Technology Regulatory Council (ITRC). Naming conventions for per- and polyfluoroalkyl substances (PFAS). 2020. 9. State of New Jersey Department of Environmental Protection- Division of Science and Research. Technical Memorandum. Subject: PFAS in artificial turf, https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo- 2023.pdf (2023). 10. Kulikov O. Novel processing aids for extrusion of polyethylene. J Vinyl Addit Technol 2005; 11: 127–131. 11. Whitehead HD. Development of analytical methods for highly selective and sensitive analysis of compounds relevant to human health and the environment, 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). 12. Glüge J, Scheringer M, Cousins IT, et al. An overview of the uses of per- And polyfluoroalkyl substances (PFAS). Environ Sci Process Impacts 2020; 22: 2345–2373. 13. 3M. 3MTM DynamarTM Polymer Processing Additives: Performance and productivity. Issued: 12/16 11949HB; 98- 0212-4231-2., https://multimedia.3m.com/mws/media/1027184O/3m-dynamar-ppas-product-comparison- guide.pdf (viewed June 4, 2024) (2016). 14. Ng CA, Hungerbühler K. Bioaccumulation of perfluorinated alkyl acids: Observations and models. Environmental Science and Technology; 48. Epub ahead of print 2014. DOI: 10.1021/es404008g. 15. Danish Ministry of the Environment. Short-chain Polyfluoroalkyl Substances (PFAS): A literature review of information on human health effects and environmental fate and effect aspects of short-chain PFAS. Environmental project No. 1707. Copenhagen, https://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-15-5.pdf (2015). 16. Swedish Chemicals Agency (KEMI). PROPOSAL FOR IDENTIFICATION OF A SUBSTANCE OF VERY HIGH CONCERN ON THE BASIS OF THE CRITERIA SET OUT IN REACH ARTICLE 57: Perfluorohexane-1-sulphonic acid and its salts, https://echa.europa.eu/documents/10162/40a82ea7-dcd2-5e6f-9bff-6504c7a226c5 (2017). 17. Toxics Use Reduction Institute (TURI). PFAS information reviewed by the Science Advisory Board, PFAS in Artificial Turf: Test Methods 11 https://www.turi.org/Our_Work/Policy/Toxics_Use_Reduction_Act/Councils_and_Committees/TURA_Science_Advi sory_Board/PFAS_information_reviewed_by_the_Science_Advisory_Board (2019, accessed 23 January 2020). 18. Cousins IT, Dewitt JC, Glüge J, et al. The high persistence of PFAS is sufficient for their management as a chemical class. Environ Sci Process Impacts 2020; 22: 2307–2312. 19. Rudin E, Glüge J, Scheringer M. Per- and polyfluoroalkyl substances (PFASs) registered under REACH—What can we learn from the submitted data and how important will mobility be in PFASs hazard assessment? Sci Total Environ; 877. Epub ahead of print 2023. DOI: 10.1016/j.scitotenv.2023.162618. 20. Brunn H, Arnold G, Körner W, et al. PFAS: forever chemicals—persistent, bioaccumulative and mobile. Reviewing the status and the need for their phase out and remediation of contaminated sites. Environ Sci Eur 2023; 35: 1–50. 21. Pickard HM, Ruyle BJ, Thackray CP, et al. PFAS and Precursor Bioaccumulation in Freshwater Recreational Fish: Implications for Fish Advisories. Environ Sci Technol 2022; 56: 15573–15583. 22. Agency for Toxic Substance and Diseas Registry. What are the health effects of PFAS?, https://www.atsdr.cdc.gov/pfas/health-effects/index.html (2024). 23. U.S. Environmental Protection Agency (EPA). Our Current Understanding of the Human Health and Environmental Risks of PFAS, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (2023). 24. U.S. Environmental Protection Agency (US EPA). PFAS Explained, https://www.epa.gov/system/files/documents/2023-10/final-virtual-pfas-explainer-508.pdf (2023). 25. Kwiatkowski CaF. Scientific Basis for Managing PFAS as a Chemical Class. Environ Sci Technol 2020; 7: 532–543. 26. U.S. Environmental Protection Agency (EPA). Converting laboratory units into consumer confidence report units, https://www.epa.gov/sites/default/files/2015-09/documents/epa816f15001.pdf. 27. Unit conversion guide available at: https://www.spex.com/getmedia/3bbc3c3a-541f-47b9-be2a- 32c9ecd54f5b/Units-of-Measurement-Infographic.pdf?ext=.pdf. 28. US Environmental Protection Agency (US EPA). Method 1633: Analysis of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS, https://www.epa.gov/system/files/documents/2024-01/method-1633-final-for-web-posting.pdf (2024). 29. Dr. Zhenyu Tian, pers.com. 30. DoD Environmental Data Quality Workgroup. Fact Sheet: Detection and Quantitation: What Project Managers and Data Users Need to Know, https://www.pjlabs.com/downloads/Fact Sheet.pdf (2017). 31. Cancer Free Economy Network. A Short Guide to Common Testing Methods for Per- and Polyfluoroalkyl Substances (PFAS) (Fact sheet, August 2020), https://www.bizngo.org/images/ee_images/uploads/resources/CFE_PFAS_Testing_FactSheet_Final.pdf (2020). 32. U.S. Environmental Protection Agency (EPA). PFAS analytical methods development and sampling research, https://www.epa.gov/water-research/pfas-analytical-methods-development-and-sampling-research (2024, accessed 8 June 2024). 33. American Society for Testing and Materials (ASTM). Standard Guide for PFAS Analytical Methods Selection, https://www.astm.org/e3302-21.html (2022). 34. US Environmental Protection Agency (US EPA). EPA Method 1312: Synthetic Precipitation Leaching Procedure. 35. Neilson L. Quick PFAS methods vs. EPA 1633: What’s right for your site?, https://www.sgs- ehsusa.com/2024/04/03/quick-pfas-methods-vs-epa-1633-whats-right-for-your-site/#:~:text=EPA 1633 is the definitive,day TAT for select projects. (2024). 36. Gillian Miller, PhD, personal communication, June 2024. 37. U.S. Environmental Protection Agency (EPA). Development of a U.S. EPA method to determine total organic fluorine in drinking water by combustion ion chromatography (CIC), https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=358977&Lab=CESER; https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9730836/ (2023). 38. Young AS, Pickard HM, Sunderland EM, et al. Organic fluorine as an indicator of per- and polyfluoroalkyl substances in dust from buildings with healthier versus conventional materials. Env Sci Technol 2022; 56: 17090–17099. 39. U.S. Environmental Protection Agency (EPA). CWA analytical methods for per- and polyfluorinated alkyl substances (PFAS), https://www.epa.gov/cwa-methods/cwa-analytical-methods-and-polyfluorinated-alkyl-substances- pfas#method-1633. 40. Hammel E, Webster TF, Gurney R, et al. Implications of PFAS definitions using fluorinated pharmaceuticals. iScience 2022; 25: 104020. 41. Peritore AF, Gugliandolo E, Cuzzocrea S, et al. Current review of increasing animal health threat of per- and PFAS in Artificial Turf: Test Methods 12 polyfluoroalkyl substances (pfas): harms, limitations, and alternatives to manage their toxicity. Int J Mol Sci 2023; 24: 11707. 42. U.S. Environmental Protection Agency (EPA). Method 1621: Determination of adsorbable organic fluorine (AOF) in aqueous matrices by combustion ion chromatography (CIC), https://www.epa.gov/system/files/documents/2024- 01/method-1621-for-web-posting.pdf (2024). 43. Houtz EF, Sedlak DL. Oxidative conversion as a means of detecting precursors to perfluoroalkyl acids in urban runoff. Environ Sci Technol 2012; 46: 9342–9349. 44. U.S. Environmental Protection Agency (EPA). Technical brief: Per- and polyfluoroalkyl substances (PFAS): Reviewing analytical methods data for environmental samples, https://www.epa.gov/sites/default/files/2019- 05/documents/technical_brief_pfas_data_review_final_19apr19-508_compliant.pdf (2019). May 5, 2025 VIA EMAIL Town of Ithaca Planning Board 215 North Tioga Street Ithaca, NY 14850 Planning@townithacany.gov Re: Site Plan Approval and Special Use Permit for Cornell University Game Farm Road Project Dear Chairperson Cameron and Members of the Planning Board, I am writing on behalf of Ithaca Residents Acting for the Environment (IRAFE) regarding the Planning Board’s consideration of the proposed site plan and special use permit for Cornell University’s Game Farm Road Athletic Complex Project. IRAFE is made up of a group of residents in the Town of Ithaca who have been concerned about the Project’s potentially harmful environmental impacts. My clients and I appreciate the Planning Board’s review of Cornell’s Project to date. In part owing to the Planning Board’s scrutiny of the Project, Cornell has made certain promises and commitments to the Planning Board about the Project that, if implemented with appropriate oversight, will further the health, safety, and general welfare of the Town. These commitments relate to the Project’s stormwater ﬁlter, third-party PFAS testing, and end-of-life recycling. My clients further appreciate that the Planning Board is considering a draft proposed resolution that contains conditions that are intended to address at least some of these commitments. The purpose of my letter is to request that the Planning Board take additional but necessary steps to ensure that these commitments are fulﬁlled by Cornell by both strengthening the language in the proposed conditions of the draft resolution and seeking additional information from Cornell. Otherwise, the Planning Board and the public will have virtually no recourse if, after the approvals are issued, these commitments are not fulﬁlled along the lines that they expect. 2 | P a g e I. The Planning Board has express and broad authority to request relevant information from Cornell relating to health and safety as well as impose reasonable conditions relating to the Project. At the outset, the Planning Board has broad authority to request information from a project applicant in furtherance of the health, safety, and general welfare of the community as part of site plan review or special use permitting.1 Along similar lines, and as reﬂected in the draft resolution, the Planning Board has authority to impose reasonable conditions on site plan approvals and special use permits, provided that the conditions are directly related to and incidental to the proposed project and further the health, safety, and general welfare of the community.2 Courts have upheld the imposition of conditions that are reasonably designed to mitigate speciﬁc concerns identiﬁed during the review process, such as environmental or public health risks.3 As the Planning Board is aware, Cornell has made representations to the Planning Board relating to the Project’s proposed stormwater ﬁlter, third-party PFAS testing, and end-of-life recycling that, if implemented eﬀectively, will further the health, safety, and general welfare of the public. By ensuring that Cornell provides requisite information about these items before issuing the approvals, the Planning Board will ensure that these commitments are fulﬁlled in a transparent and open process, and in a manner accessible to the concerned members of the public. Indeed, Cornell has already committed to each of the following items, so requesting additional information from Cornell on these subjects should not be objectionable or controversial. 1. The Project’s Stormwater Filter must be incorporated into Cornell’s Stormwater Pollution Prevention Plan (SWPPP). Cornell has represented to the Planning Board that water falling onto the artiﬁcial turf ﬁeld will be conveyed to a proprietary ﬁlter practice that uses membrane ﬁlter cartridges to capture microplastic particles down to 0.025 1 Town Code § 270-186 (site plan review may include “such additional items as may be reasonably requested by the Planning Board”); § 270-198(B)(1)(e) (Board may consider “[s]uch other information or documentation as may be deemed reasonably necessary or appropriate”). 2 See N.Y. Town Law § 274-a(4) (site plan approval) and § 274-b (special use permits). 3 Twin Town Little League, Inc. v. Town of Poestenkill, 249 A.D.2d 811, 813 (3d Dept. 1998) (“There is no question that the Board had the authority to attach conditions to its approval of petitioner’s site plan provided they were reasonable, directly related to and incidental to the proposed use of the property and were aimed at minimizing the adverse impact” that would result from such approval); St. Onge v. Donovan, 71 N.Y.2d 507, 516 (1988) (conditions can readily relate to emissions of pollutants that are “incidental to comfort, peace, enjoyment, health or safety of the surrounding area.”) 3 | P a g e millimeters (the Stormwater Filter), thereby reducing the particles that may otherwise be discharged to ground or surface waters in stormwater runoﬀ. Cornell Site Plan Review Application Report at 15. The Stormwater Filter is a proposed postconstruction stormwater management practice that is intended to protect water quality. The Town Code requires Cornell to submit a full SWPPP for this Project.4 A full SWPPP is intended to address both erosion and sediment control during construction and postconstruction stormwater management measures.5 Under the Town Code, a full SWPPP must include the following information regarding each identiﬁed postconstruction stormwater management practice: • A description of each permanent postconstruction stormwater management practice; • Site map/construction drawing(s) showing the speciﬁc location(s) and size(s) of each permanent postconstruction stormwater management practice; • Dimensions, material speciﬁcations and installation details for each permanent postconstruction stormwater management practice, including site/construction drawing(s) specifying the location(s), size(s), and length(s) of each stormwater management practice; and • Maintenance and operating procedures and schedules to ensure continuous and eﬀective operation of each permanent postconstruction stormwater management practice.6 Cornell’s proposed SWPPP dated April 16, 2025 (T.G. Miller, P.C.) fails to include this requisite information regarding the proposed Stormwater Filter. The SWPPP does not include a description of the Stormwater Filter, nor does it include any of the requisite drawings, material speciﬁcations, and installation details for the Stormwater Filter. Instead, in comparison to the detailed information about other post-construction stormwater controls, the Narrative of the SWPPP states only as follows about the Stormwater Filter: “Although not required for the project to receive SPDES permit coverage, a proprietary stormwater ﬁlter practice will be installed downstream of the ﬁeld hockey ﬁeld.” SWPPP pg. 16. Further, although certain excerpted manufacturer information has been provided in Volume II of the SWPPP regarding recommended inspection and maintenance guidelines for the Stormwater Filter, nothing in the SWPPP purports to require that Cornell adhere to any of these recommendations “to ensure continuous and eﬀective operation” of 4 Town Code § 228-6(D). 5 Id. 6 Town Code § 228-10(D)(7)-(13). 4 | P a g e the Filter.7 Yet for every other stormwater management practice at the site, the SWPPP includes a detailed maintenance schedule. The Stormwater Filter must therefore be fully incorporated into the SWPPP the same as any other identiﬁed postconstruction stormwater management practice as required by the Town Code. The Planning Board cannot consider issuing any site plan approval or special use permit for the Project until the Stormwater Filter is incorporated as required into the SWPPP.8 2. Cornell’s commitment to having the artiﬁcial turf product tested by a third party for the presence of PFAS must be fulﬁlled according to industry-standard protocols for detecting PFAS in synthetic turf materials. Cornell has chosen to use for its artiﬁcial turf ﬁeld the “Greenﬁelds TX Pro Plus” product manufactured by TenCate. Cornell has represented that this product was selected in order to reduce the Project’s environmental impacts. Speciﬁcally, Cornell understands from the manufacturer that the product is “PFAS-free” and will comply with the New York State Carpet Collection Program Law. Cornell states further that it is “committed to having the product 3rd party tested prior to leaving the manufacturer (pre-shipment)” to ensure the product remains PFAS- free. Cornell Supplemental Materials Submission at 10 (Jan. 31, 2025) (“Supp. Submission”). The Planning Board has included the following proposed condition in its draft resolution for the Project: Submission to the Planning Department of testing results from an independent laboratory (not aﬃliated with Cornell or the manufacturer) that conducts third party testing of the artiﬁcial turf materials for the presence of any perﬂuoroalkyl and polyﬂuoroalkyl substances (PFAS) before the artiﬁcial turf materials leave the manufacturer. The artiﬁcial turf materials must comply with NYS Department of Environmental Conservation (DEC) and US Environmental Protection Agency (EPA) laws and regulations, including the requirements of the NYS Carpet Collection Program Law…which states that “no carpet sold or oﬀered for sale in the state shall contain or be treated with PFAS substances for any purpose,” even though that requirement is not eﬀective until the end of 2026…. The Planning Board’s proposed inclusion of this condition is commendable. Yet without speciﬁc requirements and safeguards regarding testing and reporting protocols, the results of any testing for the presence of PFAS are very likely to be either incomplete, inaccurate, or misleading. 7 Town Code § 228-10(D)(13). 8 See Town Code § 228-10(A). 5 | P a g e The University of Massachusetts Lowell Center for Sustainable Production states that “PFAS testing includes a variety of methods and approaches,” and that “it is essential to understand the scope and limitations of any tests that are used in decision-making.”9 As described below, the Planning Board should ensure that both Targeted and Non-Targeted PFAS analyses are performed as part of any testing. “Targeted PFAS analysis” includes methods used to gather information about a speciﬁc, targeted list of PFAS chemicals, often by measuring their quantity. EPA’s Method 1633 (published 2024) is one of the leading methodologies for targeted PFAS analysis in solid materials. However, “targeted testing of individual PFAS compounds” may “only provide information on a limited number of compounds and for speciﬁc sample types.”10 “Existing targeted analyses for PFAS only measure a small number of the nearly 15,000 PFAS that exist.”11 Thus, “[l]ack of detection of these individual chemicals [in a targeted analysis] does not indicate that all PFAS are absent.”12 “Non-Targeted PFAS Analysis,” on the other hand, includes methods that “have been developed to understand the presence or concentrations of all PFAS in a sample.”13 Examples include Total Fluorine Analysis, which does not measure or identify individual PFAS compounds, but is a “useful ﬁrst step to determining the likelihood of the presence of PFAS in a sample.” And Total Oxidizable Precursor Assay, which allows “researchers to indirectly assess the presence of a wide range of PFAS, many of which are missed by targeted methods.” While DEC will likely eventually develop preferred testing and reporting protocols for complying with the NYS Carpet Collection Program Law, DEC is only “in the preliminary stage of developing new…regulations to support implementation” of the Law14 and therefore such guidance will not be available before the testing for the Project is completed. It is therefore incumbent upon the Planning Board and the Planning Department to specify industry-standard testing and reporting guidelines for the Project in the approvals. 9 PFAS in Artiﬁcial Turf: Test Methods, Lowell Center for Sustainable Production, University of Massachusetts Lowell (July 2024), attached hereto. 10 Id. 11 Id. 12 Id. 13 Id. 14 See Notice of Carpet EPR Pre-Rulemaking Stakeholder Meeting, available at https://dec.ny.gov/environmental-protection/recycling-composting/carpet 6 | P a g e Accordingly, we have provided in red additional language to the draft PFAS testing condition, adding industry-standard speciﬁcations and protocols as recommended by the Lowell Center and other leading authorities: Submission to the Planning Department of unredacted testing results from an independent laboratory (not aﬃliated with Cornell or the manufacturer) that conducts third party testing of the artiﬁcial turf materials for the presence of any perﬂuoroalkyl and polyﬂuoroalkyl substances (PFAS) before the artiﬁcial turf materials leave the manufacturer. The independent laboratory shall have experience analyzing PFAS in plastic materials. The testing results that are provided to the Planning Department shall include the results of each of the following analyses for the purposes of identifying the presence of PFAS in the artiﬁcial turf materials: 1. Targeted PFAS Analysis using EPA Method 1633; 2. Total and SPLP PFAS Analysis, using the isotope dilution method. Prior to analysis, the SPLP PFAS samples should be processed per EPA Method 1312; 3. Total Oxidizable Precursor (TOP) Assay of PFAS; 4. Total Organic Fluorine Analysis, analyzing for total ﬂuorine. All reporting and detection limits shall be measured in parts per trillion (ppt). The testing results shall identify the laboratory’s choice of extraction solvent. Upon receipt by the Planning Department, the testing results shall be available to the public to the extent provided under the Freedom of Information Law (FOIL). The artiﬁcial turf materials must comply with NYS Department of Environmental Conservation (DEC) and US Environmental protection Agency (EPA) laws and regulations, including the requirements of the NYS Carpet Collection Program Law…which states that “no carpet sold or oﬀered for sale in the state shall contain or be treated with PFAS substances for any purpose,” even though that requirement is not eﬀective until the end of 2026…. We urge the Planning Board to include this additional proposed language as part of any ﬁnal approvals for the Project. 3. Cornell’s commitment to having the turf product recycled at the end of its useful life must be detailed in an end-of-life management plan as a condition of the issuance of site plan approval or a special use permit. The artiﬁcial turf ﬁeld has a useful life of approximately 10-12 years, and numerous concerns have been raised by concerned members of the public about the methods that will be used to dispose of the product at that time, including from the Town’s Conservation Board. Cornell has therefore represented that it is “fully committed to recycling the turf at the end of its useful life,” and that it will 7 | P a g e “investigate and select the most environmentally responsible option [for disposal] available [at the time of disposal].” Supp. Submission at 12. Currently, however, the options for recycling such materials are either non- existent or extremely limited, depending on the speciﬁc product used and its manufacturer. Indeed, the Planning Board has acknowledged that the recycling options for this type of turf ﬁeld are limited currently. If recycling options are not developed over time as hoped, or if the ownership of the ﬁeld were to change hands in the future, the turf ﬁeld may not be recycled as planned or it may be left in place well after the end of its useful life, posing a long-term risk to the surrounding area and environment. The draft resolution includes the following condition regarding this topic: “Per Cornell’s commitment to recycle 100% of the artiﬁcial turf materials in the project, once said materials are at the end of their life, submission to the Planning Department of a detailed recycling plan, including the facility that is chosen to receive said materials, and submission of proof from the facility that it accepted and recycled said materials.” While the draft condition is a step in the right direction, it imposes a vague obligation on Cornell roughly a decade into the future that may be lost or forgotten during the intervening years, either because personnel changes at the Town or Cornell over time, the site is later transferred to a third party, or some other unforeseen circumstance. The Planning Board must therefore obtain additional information from Cornell regarding its disposal plan before either site plan approval or a special use permit is issued for the Project in the form of an end-of-life management plan. Such end-of-life planning during site plan review is common for other types of projects in the Town such as solar projects (Town Code § 270-219.1(G)(2)(c)(4)(i)) or cell phone towers (§ 270-219(P)). The end-of-life management plan for this Project should include at least the following elements: • A description of the anticipated useful life of the artiﬁcial turf ﬁeld, including a description of the criteria that will be used to determine when the ﬁeld has reached the end of its useful life; • A description of the anticipated means and methods for uninstalling and removing the artiﬁcial turf ﬁeld and its component parts, along with a timeline for doing so; • A commitment to recycle the artiﬁcial turf ﬁeld materials to the fullest extent possible at the end of the ﬁeld’s useful life, including a description of the means and methods to be used to recycle the artiﬁcial turf ﬁeld materials including any mitigation plan for treating and handling toxic byproducts of plastics recycling; 8 | P a g e • An identiﬁcation of the recycling facility that will be used, along with a letter of commitment from the recycling facility in question; • A description of the means and methods to be employed to dispose of the artiﬁcial turf materials if recycling is later determined to be infeasible or unavailable at the time of disposal, including an identiﬁcation of the most environmentally friendly alternative; and • A requirement to supply an updated end-of-life management plan to the Planning Board at least every four years and no less than six months before the anticipated end-of-life of the artiﬁcial turf ﬁeld materials. While the components of any end-of-life management plan should be considered by the Planning Board before any approvals are issued, at a minimum, the development and timely submission of the foregoing plan should be incorporated as a condition of approval. I am available to answer any questions about the foregoing requests and proposed conditions at the convenience of the Planning Board. Please incorporate this correspondence into any administrative record for the Project. Thank you for your time and consideration. Respectfully submitted,   Stephen D. Daly, Esq.  Citizen Environmental Law PLLC 6 N. Main St. Ste. 200-J  Fairport, NY 14450  (585) 305-1945  sdaly@citizenenvironmental.com 1 From:Carver Hauptman <cdh235@cornell.edu> Sent:Tuesday, May 6, 2025 11:04 AM To:Town Of Ithaca Planning Cc:pbstaff@cityofithaca.org Subject:Comment for tonight's Planning Board Meeting Attachments:PFAS_Testing_Request_Cornell_Turf_ZeroWasteIthaca_May2025.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 Good morning, I would like to submit the following comment to be read tonight at the planning board meeting. I have also attached a PDF to retain the formatting in case it is altered in the email. Thank you and have a great day! Best, Carver Hauptman To the Town of Ithaca Planning Board, The FOILed document revealing DEC’s concerns about stormwater impacts underscores the urgency of addressing the serious environmental risks posed by synthetic turf—especially the potential for PFAS and microplastic contamination. These substances are persistent, bioaccumulative, and harmful to ecological and human health, which is precisely why they are known as “forever chemicals.” If the Planning Board is considering any approval of the site plan for this project, it must, at minimum, require Cornell University to commit to publicly transparent, independently verified testing on representative samples of the proposed synthetic turf system. This testing must go beyond manufacturer claims and include:  Total Fluorine Testing (TF): to detect the presence of fluorine, a key indicator of PFAS;  EPA Method 1633, performed on cryo-milled samples, to detect extractable PFAS embedded in the plastic;  Additional cryo-milling tests to identify polymeric PFAS not covered by EPA Method 1633, including PTFE (Teflon) and PVDF (polyvinylidene fluoride), both of which are commonly used in synthetic turf systems and are not detectable through conventional PFAS testing methods. This broader scope of testing is critical, especially given the well-documented microplastic pollution associated with synthetic turf. These concerns are supported not only by peer-reviewed scientific studies but also by videos previously submitted to this Board as public comment. These videos were taken by grassroots volunteers around the country and offer direct visual documentation of turf fields shedding plastic fragments and filling waterways and soil with synthetic debris. Detection of PFAS in any of these scientifically valid tests would indicate noncompliance with New York State’s Carpet Collection Program Law (Article 27, Title 33 of the Environmental Conservation Law), which prohibits carpet-like products with intentionally added PFAS. Synthetic turf clearly qualifies as a plastic-backed, carpet-like flooring product. 2 The law defines PFAS broadly as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom,” consistent with the international standard adopted by the OECD. Any detection of PFAS—by any of the scientifically valid methods listed above—would show that Cornell’s proposed turf violates this state law and that its public representations about product safety are misleading. Last week, Zero Waste Ithaca obtained a sample of GreenFields TX Pro—the infill-free, so-called “PFAS-free” turf Cornell selected for the Game Farm Road field hockey field. This sample is being prepared to be sent to three independent laboratories, with a clear chain-of-custody record. It is unacceptable that the burden of conducting and funding this level of testing has been placed on an all-volunteer organization like ours. Meanwhile, the Planning Board has continued to accept Cornell’s misleading claim that “independent, third-party” testing conducted “prior to leaving the manufacturer (pre-shipment)” (January 31, 2025, Supplemental Materials Submission, p. 10) constitutes credible oversight. This is not credible, not transparent, and not compliant. It does not meet the standards required under SEQRA, which obligates the Town to independently verify environmental claims—not to delegate oversight to the applicant. We expect results in the coming weeks and will share them publicly. If PFAS is detected, it will confirm that Cornell’s proposed turf is illegal under New York law and that the public has been misled. To date, Cornell has only offered testing that is conducted by or under the control of its turf manufacturer. The limited scope of EPA Method 1633—which does not detect polymeric PFAS—along with the absence of chain-of-custody documentation and a lack of public oversight, fails to satisfy these obligations. We have raised this concern repeatedly throughout the SEQR process for both the Game Farm Road and Meinig Fieldhouse projects. Nonetheless, our concerns have been dismissed by City and Town Planning Board members who voted for negative declarations for both projects. The public deserves better. To protect the health of our soil, water, and communities, truly independent and publicly accountable testing must be required before any further action is taken. Sincerely, Carver Hauptman *The PDF is attached* Subject: Public Oversight and Independent PFAS Testing Needed Before Approving Cornell Turf Dear Town of Ithaca Planning Board members, The FOILed document revealing DEC’s concerns about stormwater impacts underscores the urgency of addressing the serious environmental risks posed by synthetic turf—especially the potential for PFAS and microplastic contamination. These substances are persistent, bioaccumulative, and harmful to ecological and human health, which is precisely why they are known as “forever chemicals.” If the Planning Board is considering any approval of the site plan for this project, it must, at minimum, require Cornell University to commit to publicly transparent, independently verified testing on representative samples of the proposed synthetic turf system. This testing must go beyond manufacturer claims and include: ● Total Fluorine Testing (TF): to detect the presence of fluorine, a key indicator of PFAS; ● EPA Method 1633, performed on cryo-milled samples, to detect extractable PFAS embedded in the plastic; ● Additional cryo-milling tests to identify polymeric PFAS not covered by EPA Method 1633, including PTFE (Teflon) and PVDF (polyvinylidene fluoride), both of which are commonly used in synthetic turf systems and are not detectable through conventional PFAS testing methods. This broader scope of testing is critical, especially given the well-documented microplastic pollution associated with synthetic turf. These concerns are supported not only by peer-reviewed scientific studies but also by videos previously submitted to this Board as public comment. These videos were taken by grassroots volunteers around the country and offer direct visual documentation of turf fields shedding plastic fragments and filling waterways and soil with synthetic debris. Detection of PFAS in any of these scientifically valid tests would indicate noncompliance with New York State’s Carpet Collection Program Law (Article 27, Title 33 of the Environmental Conservation Law), which prohibits carpet-like products with intentionally added PFAS. Synthetic turf clearly qualifies as a plastic-backed, carpet-like flooring product. The law defines PFAS broadly as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom,” consistent with the international standard adopted by the OECD. Any detection of PFAS—by any of the scientifically valid methods listed above—would show that Cornell’s proposed turf violates this state law and that its public representations about product safety are misleading. Last week, Zero Waste Ithaca obtained a sample of GreenFields TX Pro—the infill-free, so-called “PFAS-free” turf Cornell selected for the Game Farm Road field hockey field. This sample is isbeing prepared to be sent to three independent laboratories, with a clear chain-of-custody record. It is unacceptable that the burden of conducting and funding this level of testing has been placed on an all-volunteer organization like ours. Meanwhile, the Planning Board has continued to accept Cornell’s misleading claim that “independent, third-party” testing conducted “prior to leaving the manufacturer (pre-shipment)” (January 31, 2025, Supplemental Materials Submission, p. 10) constitutes credible oversight. This is not credible, not transparent, and not compliant. It does not meet the standards required under SEQRA, which obligates the Town to independently verify environmental claims—not to delegate oversight to the applicant. We expect results in coming weeks and will share them publicly. If PFAS is detected, it will confirm that Cornell’s proposed turf is illegal under New York law and that the public has been misled. To date, Cornell has only offered testing that is conducted by or under the control of its turf manufacturer. The limited scope of EPA Method 1633—which does not detect polymeric PFAS—along with the absence of chain-of-custody documentation and a lack of public oversight, fails to satisfy these obligations. We have raised this concern repeatedly throughout the SEQR process for both the Game Farm Road and Meinig Fieldhouse projects. Nonetheless, our concerns have been dismissed by City and Town Planning Board members who voted for negative declarations for both projects. The public deserves better. To protect the health of our soil, water, and communities, truly independent and publicly accountable testing must be required before any further action is taken. Sincerely, Carver Hauptman 1 From:Zero Waste Ithaca <info@zerowasteithaca.org> Sent:Tuesday, May 6, 2025 8:37 AM To:Town Of Ithaca Planning Cc:pbstaff@cityofithaca.org; Brian.Nicholson@dec.ny.gov; dep.r7@dec.ny.gov; deppermitting@dec.ny.gov Subject:Request for Rescission: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project May 6, 2025Re: Request for Rescission: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project Re: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project To: Town of Ithaca Planning Board Members Cc: NYS Department of Environmental Conservation, Region 7 Dear Town of Ithaca Planning Board Members, We are writing to formally request that the Town of Ithaca rescind the March 18 Negative Declaration issued for Cornell’s synthetic turf project at Game Farm Road and initiate a Generic Environmental Impact Statement (GEIS) to evaluate its broader environmental impacts. 1. SEQR Violations: Flawed Stormwater Review A Freedom of Information Law (FOIL) request revealed that both the NYS DEC and the Town’s engineer raised unresolved concerns about the project’s stormwater modeling, including:  Reliance on outdated 2003 models that misclassify turf fields with underdrains as "pervious" (contradicting current DEC guidance);  Retroactive “Satisfied” notations added to the Town Engineer’s memo after the March 18 Negative Declaration (NEDEC) was issued—with no supporting documentation and no public disclosure. These actions fail to meet SEQR’s "hard look" requirement (6 NYCRR § 617.7(b)) and warrant rescission of the NegDec under § 617.7(f) because:  New information (the post-hoc "satisfied" markings) proves the review was incomplete;  Material omissions hid DEC’s concerns during the SEQR process;  DEC’s objections about improper modeling remain unaddressed. The April 26 scratched-out engineering memo was not part of the record at the time the NegDec was issued. Nor was DEC’s concern about outdated runoff assumptions ever resolved. If DEC has reviewed and approved the revised modeling, no documentation of that approval appears in the public record. This warrants a formal rescission of the NegDec and further environmental review. Attached: FOIL Packet GFR Field Turf 2025 03-31-pages-2.pdf 2 2. PFAS Testing Failures and Legal Noncompliance The Town’s approval ignores Cornell’s failure to conduct independent, verifiable PFAS testing, as required to comply with:  NY’s Carpet Collection Program Law (ECL § 27-3313), which bans PFAS defined as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom” in carpet-like products (including synthetic turf);  The Planning Board’s duty under SEQR to base its determination on credible, publicly available information. We urge the Town to require testing that meets the following standards: 1. Total Fluorine testing to detect the presence of PFAS; 2. EPA Method 1633, with cryo-milling, to identify extractable PFAS; 3. Additional screening for polymeric PFAS (e.g., PTFE, PVDF) not detected by standard methods. Cornell’s current plan—relying on testing “prior to leaving the manufacturer (pre-shipment)” (January 31, 2025, Supplemental Materials Submission, p. 10) —is not independent nor transparent. Zero Waste Ithaca has secured a sample of Greenfields TX Pro and is funding independent third-party testing. Results are expected in the coming weeks. 3. Legal and Legislative Context  The Article 78 case is still active. Our standing was upheld in court, and an appeal is being prepared. Cornell’s strategy to challenge our right to sue failed. The merits of the case—including deficiencies in the SEQR process—are still under legal review.  Legislative momentum is growing:  NYS S6868 / A4021 would ban synthetic turf in schools and municipal parks statewide.  NYC Bill Int. 0983-2023 now has over 10 co-sponsors, reflecting rising concern at the city level. We respectfully request that the Planning Board:  Rescind the March 18 Negative Declaration under 6 NYCRR § 617.7(f);  Do not approve the site plan;  Initiate a Generic Environmental Impact Statement (GEIS) to assess the full scope of Cornell’s synthetic turf expansion, including cumulative impacts across multiple projects;  Suspend further consideration of this project until: o Stormwater modeling is corrected to reflect DEC standards; o Independent PFAS testing results—currently underway—are made public and reviewed by the Town. The record as it stands is incomplete and cannot support responsible or lawful project approval. 3 Respectfully submitted, Zero Waste Ithaca info@zerowasteithaca.org References: Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Bibliography. Updated May 5, 2025. https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-s_4bfbmO26R- Q/edit?usp=sharing 1 From:Zero Waste Ithaca <info@zerowasteithaca.org> Sent:Tuesday, May 6, 2025 8:00 AM To:Town Of Ithaca Planning Cc:pbstaff@cityofithaca.org Subject:Request for Rescission: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project Attachments:FOIL Packet GFR Turf 2025 03 31-pages-2.pdf; ZWI_Request_for_Rescission_NegDec_CornellTurf_2025-05-06.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 May 6, 2025 Re: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project To: Town of Ithaca Planning Board Members Cc: NYS Department of Environmental Conservation, Region 7 Dear Town of Ithaca Planning Board Members, We are writing to formally request that the Town of Ithaca rescind the March 18 Negative Declaration issued for Cornell’s synthetic turf project at Game Farm Road and initiate a Generic Environmental Impact Statement (GEIS) to evaluate its broader environmental impacts. 1. SEQR Violations: Flawed Stormwater Review A Freedom of Information Law (FOIL) request revealed that both the NYS DEC and the Town’s engineer raised unresolved concerns about the project’s stormwater modeling, including:  Reliance on outdated 2003 models that misclassify turf fields with underdrains as "pervious" (contradicting current DEC guidance);  Retroactive “Satisfied” notations added to the Town Engineer’s memo after the March 18 Negative Declaration (NEDEC) was issued—with no supporting documentation and no public disclosure. These actions fail to meet SEQR’s "hard look" requirement (6 NYCRR § 617.7(b)) and warrant rescission of the NegDec under § 617.7(f) because:  New information (the post-hoc "satisfied" markings) proves the review was incomplete;  Material omissions hid DEC’s concerns during the SEQR process;  DEC’s objections about improper modeling remain unaddressed. The April 26 scratched-out engineering memo was not part of the record at the time the NegDec was issued. Nor was DEC’s concern about outdated runoff assumptions ever resolved. If DEC has reviewed and approved the revised modeling, no documentation of that approval appears in the public record. This warrants a formal rescission of the NegDec and further environmental review. Attached: FOIL Packet GFR Field Turf 2025 03-31-pages-2.pdf 2 2. PFAS Testing Failures and Legal Noncompliance The Town’s approval ignores Cornell’s failure to conduct independent, verifiable PFAS testing, as required to comply with:  NY’s Carpet Collection Program Law (ECL § 27-3313), which bans PFAS defined as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom” in carpet-like products (including synthetic turf);  The Planning Board’s duty under SEQR to base its determination on credible, publicly available information. We urge the Town to require testing that meets the following standards: 1. Total Fluorine testing to detect the presence of PFAS; 2. EPA Method 1633, with cryo-milling, to identify extractable PFAS; 3. Additional screening for polymeric PFAS (e.g., PTFE, PVDF) not detected by standard methods. Cornell’s current plan—relying on testing “prior to leaving the manufacturer (pre-shipment)” (January 31, 2025, Supplemental Materials Submission, p. 10) —is not independent nor transparent. Zero Waste Ithaca has secured a sample of Greenfields TX Pro and is funding independent third-party testing. Results are expected in the coming weeks. 3. Legal and Legislative Context  The Article 78 case is still active. Our standing was upheld in court, and an appeal is being prepared. Cornell’s strategy to challenge our right to sue failed. The merits of the case—including deficiencies in the SEQR process—are still under legal review.  Legislative momentum is growing:  NYS S6868 / A4021 would ban synthetic turf in schools and municipal parks statewide.  NYC Bill Int. 0983-2023 now has over 10 co-sponsors, reflecting rising concern at the city level. We respectfully request that the Planning Board:  Rescind the March 18 Negative Declaration under 6 NYCRR § 617.7(f);  Do not approve the site plan;  Initiate a Generic Environmental Impact Statement (GEIS) to assess the full scope of Cornell’s synthetic turf expansion, including cumulative impacts across multiple projects;  Suspend further consideration of this project until: o Stormwater modeling is corrected to reflect DEC standards; o Independent PFAS testing results—currently underway—are made public and reviewed by the Town. The record as it stands is incomplete and cannot support responsible or lawful project approval. 3 Respectfully submitted, Zero Waste Ithaca info@zerowasteithaca.org References: Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Bibliography. Updated May 5, 2025. https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-s_4bfbmO26R- Q/edit?usp=sharing 1 Paulette Rosa From:David Oshea <DOshea@townithacany.gov> Sent:Thursday, April 10, 2025 2:58 PM To:Paulette Rosa Subject:FW: SPDES Permit Review Question - Town of Ithaca David O'Shea, P.E. Director of Engineering/Town Engineer Town of Ithaca 607-273-1656 ext 257 From: Nicholson, Brian M (DEC) <Brian.Nicholson@dec.ny.gov> Sent: Monday, December 2, 2024 3:33 PM To: Justin McNeal <JMcNeal@townithacany.gov> Cc: David Oshea <DOshea@townithacany.gov>; Hanas, Debra (DEC) <Debra.Hanas@dec.ny.gov>; Emily Rodgers <erodgers@townithacany.gov> Subject: RE: SPDES Permit Review Question - Town of Ithaca Hi JusƟn, I reviewed a design manual from Aug. 2003 and I didn’t ﬁnd the requirement to model ag land as meadow cover type back then, so I don’t want to hold them to that design standard from the design they developed in 2002/3. They can design the stormwater pracƟces based on the current site as exisƟng condiƟons and design the stormwater pracƟces accordingly to the new development. If your team has documentaƟon showing they were required to meet “Meadow cover” during the 2003 design, then we can look at holding them to that design standard. Thanks, Brian Brian M. Nicholson, P.E. Professional Engineer 1 (Env.) Region 7, Division of Water New York State Department of Environmental Conservation 5786 Widewaters Parkway, Syracuse, NY 13214-1867 P: 315-426-7530 | F: 315-426-7459 | brian.nicholson@dec.ny.gov www.dec.ny.gov | | From: Nicholson, Brian M (DEC) Sent: Wednesday, November 27, 2024 3:58 PM To: Justin McNeal <JMcNeal@townithacany.gov> Cc: David Oshea <DOshea@townithacany.gov>; Hanas, Debra (DEC) <Debra.Hanas@dec.ny.gov>; Emily Rodgers 2 <erodgers@townithacany.gov> Subject: RE: SPDES Permit Review Question - Town of Ithaca Hi JusƟn, I’ve sent out a couple of emails to see what my colleagues think about this situaƟon. I’ll get back to you next week with an answer. Thanks, Brian From: Justin McNeal <JMcNeal@townithacany.gov> Sent: Wednesday, November 27, 2024 8:07 AM To: Hanas, Debra (DEC) <Debra.Hanas@dec.ny.gov>; Nicholson, Brian M (DEC) <Brian.Nicholson@dec.ny.gov> Cc: David Oshea <DOshea@townithacany.gov>; Emily Rodgers <erodgers@townithacany.gov> Subject: SPDES Permit Review Question - Town of Ithaca ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails. Good Morning Deb and Brian, We would like some clariﬁcation regarding a proposed project in the Town of Ithaca. The project is proposing to convert an existing natural turf grass ﬁeld with underdrains into a synthetic turf ﬁeld along with a few small buildings, spectator facilitie total of 4 natural turf grass ﬁelds with underdrains, a gravel parking lot and driveway, and a metal building with locker rooms and bathrooms. As part of the original project in 2003, 2 stormwater ponds were installed for both water quality treatment and quantity attenuation. wetland practice. At the time the SWPPP was approved in 2003, the applicant modeled the precondition as row crop. Only one of the natural grass turf ﬁelds will be disturbed during this project, the remaining 3 with remain undisturbed. Now that they are proposing to remove the 2 stormwater ponds with this project and install a new practice for attenuation, we are thinking the applicant should model the pre-condition as meadow prior to the 2003 project not the current pond outﬂows (which are based on the natural turf ﬁelds with under drains being considered a pervious surface). Our rational is based on recent guidance received from DEC pertaining to natural turf ﬁelds with underdrains being considered an impervious surface. How should this be handled? Should the applicant be required to re-evaluate the quantity attenuation for the entire site with the pre-construction condition being the condition prior to the 2003 project or can they use the pre- condition as the pond discharge rates which were developed based on the ﬁelds being considered as pervious? The question is ultimately being posed because a new attenuation practice is being installed to replace the ponds. Sincerely, Justin McNeal Civil Engineer Town of Ithaca Engineering Dept. 114 Seven Mile Drive Ithaca, NY 14850 Some people who received this message don't often get email from jmcneal@townithacany.gov. Learn why this is important 3 W: (607)-273-1656 Ext. 260 C: (607)-220-8342 1 Paulette Rosa From:David Oshea <DOshea@townithacany.gov> Sent:Thursday, April 10, 2025 2:58 PM To:Paulette Rosa Subject:FW: Game Farm Field Hockey Project Engineering Review Memo David O'Shea, P.E. Director of Engineering/Town Engineer Town of Ithaca 607-273-1656 ext 257 From: Justin McNeal <JMcNeal@townithacany.gov> Sent: Tuesday, December 10, 2024 10:47 AM To: Chris Balestra <CBalestra@townithacany.gov>; David Oshea <DOshea@townithacany.gov>; Emily Rodgers <erodgers@townithacany.gov> Cc: Abby Homer <ahomer@townithacany.gov> Subject: RE: Game Farm Field Hockey Project Engineering Review Memo Hello Chris, Yep, we would like to send them out to the applicant team so they can get a jump on the comments. We have had a couple of quick conversations with the Engineer, they have asked if we had reviewed the materials submitted and if we have any comments. We understand that they may need to change things as the Planning Board reviews materials, but we are also trying to coordinate reviews between the multiple Dev Rev projects. We would like to have this comment letter out to them before they send in the next set of revisions to limit the number of times we are reviewing the materials. Thank You, Justin McNeal Civil Engineer Town of Ithaca Engineering Dept. 114 Seven Mile Drive Ithaca, NY 14850 W: (607)-273-1656 Ext. 260 C: (607)-220-8342 From: Chris Balestra <CBalestra@townithacany.gov> Sent: Tuesday, December 10, 2024 10:30 AM To: Justin McNeal <JMcNeal@townithacany.gov>; David Oshea <DOshea@townithacany.gov>; Emily Rodgers <erodgers@townithacany.gov> Cc: Abby Homer <ahomer@townithacany.gov> Subject: RE: Game Farm Field Hockey Project Engineering Review Memo 2 Thanks Justin. This information is fantastic, but extremely premature. The PB hasn’t even decided to be the lead agency in the environmental review. And there’s a good chance that plans (and SWPPP) will need modiﬁcation, as the project does go through the environmental review. We are about two steps away from that now. Are you sure you don’t want to hang onto these comments until a later phase of review (e.g., SEQR determination, or preliminary site plan review)? Christine Balestra, Senior Planner Town of Ithaca Planning Department 215 North Tioga Street Ithaca, NY 14850 (607) 273-1721, ext. 121 cbalestra@townithacany.gov From: Justin McNeal <JMcNeal@townithacany.gov> Sent: Friday, December 6, 2024 10:53 AM To: Chris Balestra <CBalestra@townithacany.gov> Cc: Abby Homer <ahomer@townithacany.gov> Subject: Game Farm Field Hockey Project Engineering Review Memo Good Morning Chris, We have completed our initial review of the Game Farm Field Hockey project. Could you please send this out to the project team? If you would like me to upload it somewhere speciﬁc instead, please let me know. Have a good weekend, Justin McNeal Civil Engineer Town of Ithaca Engineering Dept. 114 Seven Mile Drive Ithaca, NY 14850 W: (607)-273-1656 Ext. 260 C: (607)-220-8342 605 W. State Street | Ithaca, NY 14850 | phone 607-272-6477 | fax 607-273-6322 | www.tgmillerpc.com David A. Herrick, P.E. Frank L Santelli, P.E. Owen B. Barden, P.E. Donald M. Harner, P.E. LEED A.P., C.P.E.S.C. Lee Dresser, L.S. Jacqueline L. Dresser, L.S. March 14, 2025 Kimberly Van Leeuwen, RLA Director of Landscape Architecture Fisher Associates 1001 W. Seneca Street Ithaca, New York 14850 Re: Cornell University Game Farm Road Field Hockey Field Town of Ithaca SWPPP Review Comments Dear Ms. Van Leeuwen: Below please find our responses to review comments dated December 6, 2024 and prepared by David O’Shea, P.E. for the above referenced project. For ease of review, original review comments are re-stated and our responses are included in bold type. Sewer: 1.Prior to Final Site Plan Approval Submission, A Sewer Exemption Request must be submitted to the Town of Ithaca Engineering Department regarding the proposed septic system. The request will go before the Public Works Committee and the Town Board for review and approval. TGM Response: Acknowledged, a sewer exemption request was submitted to the Town by Cornell University on March 7, 2025. 2.All plan sheets should be updated to show the existing septic system filter area and proposed filter area. These areas should be delineated to be protected during construction. TGM Response: The existing septic system is noted on all project drawings and notes are added to protect these areas. Stormwater: 1.The complete SWPPP and associated documents will need to be uploaded to OpenGov under a SWPPP application and fee paid once they have been approved. TGM Response: The SWPPP will be uploaded to OpenGov and the application fee will be paid. 2.Revise the table of contents to correct page numbers and remove unused chapters. TGM Response: The table of contents has been revised accordingly. 3.Please update the SWPPP to include information and associated requirements for seeking a 5-ac waiver for disturbance. TGM Response: Page 1 of the SWPPP includes language regarding the need for written authorization prior to disturbing 5 acres. T.G. Miller, P.C. 2 4.Please indicate which version of the New York State Stormwater Management Design Manual was used for this project. TGM Response: The 2015 New York State Stormwater Management Desing Manual was used for the project. 5.Please update the Vol. I narrative regarding fill sites. If the fill site is within an MS4, the MS4 must approve the site and sign onto the SWPPP. TGM Response: Based on recent communications with NYSDEC Region 7 Staff, we have learned that remote fill sites (i.e. greater than ¼-mile from the project) do not need to sign onto the project SWPPP. It is still the responsibility of any fill site owner to comply with local and NYSDEC regulations pertaining to soil disturbance activities on the land of those fill sites. The written communications between TGM and NYSDEC will be shared with the Town Engineer. The SWPPP has been revised to reflect this. 6.Please update the SWPPP narrative to correctly and consistently identify the onsite soil groups. Dual soil groups are identified in the mapping. Please elaborate on what value you are using and why. TGM Response: The dual soil groups identified in the USDA soil survey have been added to on-site soil section of the SWPPP narrative. For areas where dual soil groups have been identified, they are assumed to have a HSG rating of “D”. This assumption is based on the onsite infiltration and percolation testing conducted (Please see response to comment #14 for additional information). Additionally, the previously approved 2003 SWPPP utilized a HSG rating of “D” for all dual soil group areas. 7.Please update existing tables or provide additional tables identifying the amount of new impervious per watershed. The map provided does not provide this information as you are modifying drainage boundaries. TGM Response: After further conversation with the Town Engineering staff this comment is no longer applicable. 8.Update the narrative to provide information on how the turf field will drain and get into the drainage system. TGM Response: The SWPPP narrative has been updated accordingly. 9.There are discrepancies between the SWPPP narrative and the site map regarding impervious and pervious acreage. Please provide clarification. If the main outer watershed boundary is not changing, Table 1 and Table 2 area summations should be equal. TGM Response: The SWPPP has been revised to address these discrepancies. 10.In Watershed 4, the narrative states the area is 11.73 acres of impervious surface, most of the area is pervious lawn. Please clarify this discrepancy. TGM Response: Existing watershed #4 has 0.86 acres of impervious cover, not 11.73. This has been revised in both the SWPPP narrative and on the existing watershed map. 11.The narrative references a Min Rv number of 0.2, but this value is not used in the water quality volume or runoff reduction calculations. Please revise the calculations accordingly. TGM Response: Calculations have been revised accordingly. T.G. Miller, P.C. 3 12.Please clarify why RRv is not being provided for impervious areas that are being disturbed. TGM Response: All existing impervious areas that will be disturbed are in Watersheds #4A and #5. The required RRv for each is 1,210 CF and 2,510 CF, respectively. Bioretention filter #1, located within watershed #4A, provides 1,716 CF of RRv while bioretention filter #2, located within watershed #5, provides 3,098 CF. It should be noted, there are sections of existing impervious area, a large portion of the gravel driveway, that is being restored to pervious lawn. 13.Please provide the borings logs as indicated in the SWPPP. They are not included. TGM Response: Boring logs have been attached to the SWPPP. 14.Please be more specific on why site limitations exist. Please include the definition and which criteria allows them to be utilized. TGM Response: Percolation testing was conducted at different locations throughout the site as part of the 2003 McGovern soccer field project geotechnical explorations. The results of these tests indicated infiltration rates of less than 0.5 in/hr. Additionally, the boring logs indicate a high prevalence of clay soils throughout the site. In support of the current project’s septic system design, T.G. Miller, P.C. conducted percolation testing. The results also indicated infiltration rates of less than 0.5 in/hr. Furthermore, the USDA soil survey report for the project indicates that the underlying soil for a large percentage of the project has hydrologic soils group rating of “D” or “C/D”. The geotechnical report has been attached to the SWPPP. 15.Sediment Traps and Sediment Basins are both called out in the narrative and plan set. Please verify which is being proposed. Please provide associated calculations and details as required by the New York State Standards and Specifications for Erosion and Sediment Control (Blue Book). TGM Response: All references to sediment traps have been removed. Sediment basin calculations and topography have been added to drawing C102. 16.Update the plan set to include a Concrete Washout Area and its associated construction detail. TGM Response: A concrete washout detail has been added to the drawings. 17.Please revise the plan set to include the following details: •Sediment Trap or Sediment Basin TGM Response: See response to comment #15. •Rock Check Dam TGM Response: A Rock Check Dam detail has been added. •Bioretention Filter Forebay and Weir. Please review this with the landscape plan relative to soils and vegetation requirements that differ between the forebay and the filter area. TGM Response: Bioretention filter and forebay plantings have been coordinated with landscape plans. •Extended Detention Short Wetland TGM Response: An enlarged plan of the extended detention ‘shallow’ T.G. Miller, P.C. 4 wetland has been added to the drawings. 18.Please add the following items to the plan set. •Include mound septic system on proposed drainage plan C105. TGM Response: The mound septic system has been added to C105. •Silt sock detail on Sheet C102 needs to be revised to match the Blue Book. TGM Response: The silt log detail on C102-3 has been revised. •Indicate material staging area on plan. Please note this area must be on a stabilized surface. TGM Response: The contractor material staging area has been added to all ESC plans. •Add winter stabilization procedures to the plan set. TGM Response: Winter stabilization notes have been to the ESC plans. •Indicate stream setbacks on all plan sheets. Please verify this setback was determined in accordance with the Code of the Town of Ithaca and accounts for any steep slopes that may be present. TGM Response: The stream setback has been added to all applicable plans where the viewport and scale allows. The stream setback shown was calculated in accordance with Town of Ithaca Code, inclusive of adjacent steep slopes. 19.Identify the length of the tracking pads. TGM Response: The length of the tracking pads has been added to the ESC plans. 20.Provide erosion and sediment control plan for phasing. TGM Response: Three erosion and sediment control plans have been prepared to reflect phasing. 21.Contour labels need to be added to the drainage plan in the stormwater practices where they are not provided on the grading plan. It would be beneficial for the contours in their entirety to be labeled on the drainage plan. TGM Response: Contour labels have been added within the extended detention shallow wetland. 22.There appears to be a difference between the drainage plan and grading plan. Please review and update accordingly. TGM Response: Drainage plan and grading plan have been coordinated. 23.The demo plan incorrectly identifies which pipe is being removed at the western pond. TGM Response: The demo plan has been revised accordingly. 24.Please review the existing catch basins and proposed grading plan. There are numerous basins around the proposed field that will need adjustments. Please review these basins and with other site improvements. There appears to be conflicts depicted in the plan set. TGM Response: Notes have been added to the drainage plan indicating rim elevation adjustments to all existing catch basins. All conflicts with site improvements have been resolved. 25.Please identify how the existing field drains (labeled tile outlet) will be handled. T.G. Miller, P.C. 5 TGM Response: Existing field drains will be daylighted into the proposed swale. A note has been added to drawing C105. 26.Update landscaping plans to identify native planting are required as mentioned in the SWPPP narrative. TGM Response: The landscaping plans have been revised accordingly. 27.The modeling of existing conditions must align with the post-conditions outlined in the 2003 SWPPP. This includes accurately representing the field conditions as pervious in the pre-condition per the 2003 SWPPP and now impervious for the post condition based on DEC’s current guidance. The ponds shall be modeled according to their post conditions in 2003 and incorporating any missing stormwater structures into the model. TGM Response: Below is a table summarizing the post-development peak discharge rates for both the 2003 McGovern SWPPP and the current CU GFR SWPPP. For the purposes of a pre- versus post-development comparison, the rates from 2003 SWPPP shall be considered as the pre-developed condition per the above Town review comment. As can be seen, the post-development peak discharge is attenuated for the 1, 10, and 100-yr storm events by the proposed stormwater management approach. The SWPPP narrative will be revised to consider the 2003 SWPPP post development runoff rates as the pre- development rates for the current project. 28.Please provide additional information supporting your design that water will be conveyed to the attenuation device. Current modeling indicates that the structures are overtopping. TGM Response: Regarding diversion structure #1, runoff that may surcharge out of the structure will be captured by downstream drainage structures. If for any reason those structures become plugged and are not able to function, then all runoff will be conveyed to the attenuation device via the overland flow path between fields 3 & 4. Regarding diversion structure #2, the HydroCAD model has been revised so that runoff is no longer surcharging. 29.There are numerous discrepancies between the plan set and the HydroCad calculations. Please revise the materials accordingly. The calculations were not reviewed in detail due to the discrepancies. TGM Response: The HydroCAD calculations have been revised to be consistent with applicable device rims, inverts, and typical details.. 30.Please add the filters to the hydraulic modeling to verify how these systems are acting during the larger storm events (are they overtopping, do the overflow catch basins handle everything, etc.). TGM Response: Both bioretention filters have been added to the HydroCAD model. 31.Diversion Structure 2 appears to be overtopping into the bioretention filter. Provide T.G. Miller, P.C. 6 calculations for the wetland as described in Chapter 6 section 1 and 2 of the Stormwater Management Design Manual. Note stormwater wetlands must also meet the requirements of Stormwater Ponds. TGM Response: The HydroCAD calculations have been revised and diversion structure #2 no longer surcharges. Calculations have been added to Volume 1 of the SWPPP. Respectfully, David A. Herrick, P.E. Comment # = Plan Revision Required Comment # = Needs to be Completed Comment # = Completed Sewer: 1. Prior to Final Site Plan Approval Submission, A Sewer Exemption Request must be submitted to the Town of Ithaca Engineering Department regarding the proposed septic system. The request will go before the Public Works Committee and the Town Board for review and approval. TGM Response: Acknowledged, a sewer exemption request will be submitted prior to final site plan. 2. All plan sheets should be updated to show the existing septic system filter area and proposed filter area. These areas should be delineated to be protected during construction. TGM Response: The existing septic system will be noted on all project drawings and notes will be added to protect these areas. Stormwater: 1. The complete SWPPP and associated documents will need to be uploaded to OpenGov under a SWPPP application and fee paid once they have been approved. TGM Response: The SWPPP will be uploaded to OpenGov and the application fee will be paid. 2. Revise the table of contents to correct page numbers and remove unused chapters. TGM Response: The table of contents has been revised accordingly. 3. Please update the SWPPP to include information and associated requirements for seeking a 5-ac waiver for disturbance. TGM Response: Page 1 of the SWPPP includes language regarding the need for written authorization prior to disturbing 5 acres. 4. Please indicate which version of the New York State Stormwater Management Design Manual was used for this project. TGM Response: The 2015 New York State Stormwater Management Desing Manual was used for the project. 5. Please update the Vol. I narrative regarding fill sites. If the fill site is within an MS4, the MS4 must approve the site and sign onto the SWPPP. TGM Response: Based on recent communications with NYSDEC Region 7 Staff, we have learned that remote fill sites (i.e. greater than ¼-mile from the project) do not need to sign onto the project SWPPP. It is still the responsibility of any fill site owner to comply with local and NYSDEC regulations pertaining to soil disturbance activities on the land of those fill sites. The written communications between TGM and NYSDEC will be shared with the Town Engineer. 6. Please update the SWPPP narrative to correctly and consistently identify the onsite soil groups. Dual soil groups are identified in the mapping. Please elaborate on what value you are using and why. TGM Response: The dual soil groups identified in the USDA soil survey have been added to on-site soil section of the SWPPP narrative. For areas where dual soil groups have been identified, they are assumed to have a HSG rating of “D”. This assumption is based on the onsite infiltration and percolation testing conducted (Please see response to comment #14 for additional information). Additionally, the previously approved 2003 SWPPP utilized a HSG rating of “D” for all dual soil group areas. 7. Please update existing tables or provide additional tables identifying the amount of new impervious per watershed. The map provided does not provide this information as you are modifying drainage boundaries. TGM Response: The proposed watershed map will be updated to distinguish between existing and new imperious cover per watershed. 8. Update the narrative to provide information on how the turf field will drain and get into the drainage system. TGM Response: The SWPPP narrative has been updated accordingly. 9. There are discrepancies between the SWPPP narrative and the site map regarding impervious and pervious acreage. Please provide clarification. If the main outer watershed boundary is not changing, Table 1 and Table 2 area summations should be equal. TGM Response: The SWPPP has been revised to address these discrepancies. 10. In Watershed 4, the narrative states the area is 11.73 acres of impervious surface, most of the area is pervious lawn. Please clarify this discrepancy. TGM Response: Existing watershed #4 has 0.86 acres of impervious cover, not 11.73. This has been revised in both the SWPPP narrative and on the existing watershed map. 11. The narrative references a Min Rv number of 0.2, but this value is not used in the water quality volume or runoff reduction calculations. Please revise the calculations accordingly. TGM Response: For watershed #4A, a Min. RRv HSG reduction factor of 0.2 was used. This value is represented on the Water Quality Volume calculation sheet included in volume II. Please note, a value of 0.3 was used for watershed #5. 12. Please clarify why RRv is not being provided for impervious areas that are being disturbed. TGM Response: All existing impervious areas that will be disturbed are in Watersheds #4A and #5. The required RRv for each is 1,210 CF and 2,510 CF, respectively. Bioretention filter #1, located within watershed #4A, provides 1,716 CF of RRv while bioretention filter #2, located within watershed #5, provides 3,098 CF. It should be noted, there are sections of existing impervious area, a large portion of the gravel driveway, that is being restored to pervious lawn. 13. Please provide the borings logs as indicated in the SWPPP. They are not included. TGM Response: Boring logs have been attached to the SWPPP. 14. Please be more specific on why site limitations exist. Please include the definition and which criteria allows them to be utilized. TGM Response: Percolation testing was conducted at different locations throughout the site as part of the 2003 McGovern soccer field project geotechnical explorations. The results of these tests indicated infiltration rates of less than 0.5 in/hr. Additionally, the boring logs indicate a high prevalence of clay soils throughout the site. In support of the current project’s septic system design, T.G. Miller, P.C. conducted percolation testing. The results also indicated infiltration rates of less than 0.5 in/hr. Furthermore, the USDA soil survey report for the project indicates that the underlying soil for a large percentage of the project has hydrologic soils group rating of “D” or “C/D”. The geotechnical report and septic percolation testing have been attached to the SWPPP. 15. Sediment Traps and Sediment Basins are both called out in the narrative and plan set. Please verify which is being proposed. Please provide associated calculations and details as required by the New York State Standards and Specifications for Erosion and Sediment Control (Blue Book). TGM Response: All references to sediment traps have been removed. Sediment basin calculations and topography have been added to drawing C102. 16. Update the plan set to include a Concrete Washout Area and its associated construction detail. TGM Response: A concrete washout detail has been added to the drawings. 17. Please revise the plan set to include the following details: • Sediment Trap or Sediment Basin TGM Response: See response to comment #15. • Rock Check Dam TGM Response: A Rock Check Dam detail has been added. • Bioretention Filter Forebay and Weir. Please review this with the landscape plan relative to soils and vegetation requirements that differ between the forebay and the filter area. TGM Response: Bioretention filter and forebay to be coordinated with landscape plans. • Extended Detention Short Wetland TGM Response: An enlarged plan of the extended detention ‘shallow’ wetland has been added to the drawings. 18. Please add the following items to the plan set. • Include mound septic system on proposed drainage plan C105. TGM Response: The mound septic system has been added to C105. • Silt sock detail on Sheet C102 needs to be revised to match the Blue Book. TGM Response: The silt log detail on C102 has been revised. • Indicate material staging area on plan. Please note this area must be on a stabilized surface. TGM Response: The material staging area will be indicated on the plans. • Add winter stabilization procedures to the plan set. TGM Response: Winter stabilization notes will be added to the plans. • Indicate stream setbacks on all plan sheets. Please verify this setback was determined in accordance with the Code of the Town of Ithaca and accounts for any steep slopes that may be present. TGM Response: The stream setback has been added to all applicable plans where the viewport and scale allows. Yes, all shown stream setbacks shown are in accordance with Town of Ithaca standards. 19. Identify the length of the tracking pads. TGM Response: The length of the tracking pads has been added to drawing C102. 20. Provide erosion and sediment control plan for phasing. TGM Response: A phased erosion and sediment control plan will be added to the drawings. 21. Contour labels need to be added to the drainage plan in the stormwater practices where they are not provided on the grading plan. It would be beneficial for the contours in their entirety to be labeled on the drainage plan. TGM Response: Contour labels have been added to the extended detention shallow wetland. 22. There appears to be a difference between the drainage plan and grading plan. Please review and update accordingly. TGM Response: Drainage plan and grading plan will be coordinated. 23. The demo plan incorrectly identifies which pipe is being removed at the western pond. TGM Response: The demo plan has been revised accordingly. 24. Please review the existing catch basins and proposed grading plan. There are numerous basins around the proposed field that will need adjustments. Please review these basins and with other site improvements. There appears to be conflicts depicted in the plan set. TGM Response: Notes have been added to the drainage plan indicating rim elevation adjustments to all existing catch basins. All conflicts with site improvements have been resolved. 25. Please identify how the existing field drains (labeled tile outlet) will be handled. TGM Response: Existing field drains will be daylighted into the proposed swale. A note has been added to drawing C105. 26. Update landscaping plans to identify native planting are required as mentioned in the SWPPP narrative. TGM Response: The landscaping plans will be revised accordingly. 27. The modeling of existing conditions must align with the post-conditions outlined in the 2003 SWPPP. This includes accurately representing the field conditions as pervious in the pre-condition per the 2003 SWPPP and now impervious for the post condition based on DEC’s current guidance. The ponds shall be modeled according to their post conditions in 2003 and incorporating any missing stormwater structures into the model. TGM Response: Below is a table summarizing the post-development peak discharge rates for both the 2003 McGovern SWPPP and the current CU GFR SWPPP. For the purposes of a pre- versus post-development comparison, the rates from 2003 SWPPP shall be considered as the pre-developed condition per the above Town review comment. As can be seen, the post-development peak discharge is attenuated for the 1, 10, and 100-yr storm events by the proposed stormwater management approach. The SWPPP narrative will be revised to consider the 2003 SWPPP post development runoff rates as the pre- development rates for the current project. 28. Please provide additional information supporting your design that water will be conveyed to the attenuation device. Current modeling indicates that the structures are overtopping. TGM Response: Regarding diversion structure #1, runoff that may surcharge out of the structure will be captured by downstream drainage structures. If for any reason those structures become plugged and are not able to function, then all runoff will be conveyed to the attenuation device via the overlayed flow path between fields 3 & 4. Regarding diversion structure #2, the HydroCAD model has been revised so that runoff is no longer surcharging. 29. There are numerous discrepancies between the plan set and the HydroCad calculations. Please revise the materials accordingly. The calculations were not reviewed in detail due to the discrepancies. TGM Response: The HydroCAD calculations have been revised to address these discrepancies. 30. Please add the filters to the hydraulic modeling to verify how these systems are acting during the larger storm events (are they overtopping, do the overflow catch basins handle everything, etc.). TGM Response: Both bioretention filters have been added to the HydroCAD model. 31. Diversion Structure 2 appears to be overtopping into the bioretention filter. Provide calculations for the wetland as described in Chapter 6 section 1 and 2 of the Stormwater Management Design Manual. Note stormwater wetlands must also meet the requirements of Stormwater Ponds. TGM Response: The HydroCAD calculations have been revised and diversion structure #2 no longer surcharges. Calculations have been added to volume 1 of the SWPPP. May 6, 2025 Re: SEQR Failures and Inadequate PFAS Oversight in Cornell’s Synthetic Turf Project To: Town of Ithaca Planning Board Members Cc: NYS Department of Environmental Conservation, Region 7 Dear Town of Ithaca Planning Board Members, We are writing to formally request that the Town of Ithaca rescind the March 18 Negative Declaration issued for Cornell’s synthetic turf project at Game Farm Road and initiate a Generic Environmental Impact Statement (GEIS) to evaluate its broader environmental impacts. 1. SEQR Violations: Flawed Stormwater Review A Freedom of Information Law (FOIL) request revealed that both the NYS DEC and the Town’s engineer raised unresolved concerns about the project’s stormwater modeling, including: ● Reliance on outdated 2003 models that misclassify turf fields with underdrains as "pervious" (contradicting current DEC guidance); ● Retroactive “Satisfied” notations added to the Town Engineer ’s memo after the March 18 Negative Declaration (NEDEC) was issued—with no supporting documentation and no public disclosure. These actions fail to meet SEQR’s "hard look" requirement (6 NYCRR § 617.7(b)) and warrant rescission of the NegDec under § 617.7(f) because: ● New information (the post-hoc "satisfied" markings) proves the review was incomplete; ● Material omissions hid DEC’s concerns during the SEQR process; ● DEC’s objections about improper modeling remain unaddressed. The April 26 scratched-out engineering memo was not part of the record at the time the NegDec was issued. Nor was DEC’s concern about outdated runoff assumptions ever resolved. If DEC has reviewed and approved the revised modeling, no documentation of that approval appears in the public record. This warrants a formal rescission of the NegDec and further environmental review. Attached: FOIL Packet GFR Field Turf 2025 03-31-pages-2.pdf 2. PFAS Testing Failures and Legal Noncompliance The Town’s approval ignores Cornell’s failure to conduct independent, verifiable PFAS testing, as required to comply with: ● NY’s Carpet Collection Program Law (ECL § 27-3313), which bans PFAS defined as “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom” in carpet-like products (including synthetic turf); ● The Planning Board’s duty under SEQR to base its determination on credible, publicly available information. We urge the Town to require testing that meets the following standards: 1. Total Fluorine testing to detect the presence of PFAS; 2. EPA Method 1633, with cryo-milling, to identify extractable PFAS; 3. Additional screening for polymeric PFAS (e.g., PTFE, PVDF) not detected by standard methods. Cornell’s current plan—relying on testing “prior to leaving the manufacturer (pre-shipment)” (January 31, 2025, Supplemental Materials Submission, p. 10) —is not independent nor transparent. Zero Waste Ithaca has secured a sample of Greenfields TX Pro and is funding independent third-party testing. Results are expected in the coming weeks. 3. Legal and Legislative Context ● The Article 78 case is still active. Our standing was upheld in court, and an appeal is being prepared.. Cornell’s strategy to challenge our right to sue failed. The merits of the case—including deficiencies in the SEQR process—are still under legal review. ● Legislative momentum is growing: ● NYS S6868 / A4021 would ban synthetic turf in schools and municipal parks statewide. ● NYC Bill Int. 0983-2023 now has over 10 co-sponsors, reflecting rising concern at the city level. We respectfully request that the Planning Board: ● Rescind the March 18 Negative Declaration under 6 NYCRR § 617.7(f); ● Do not approve the site plan; ● Initiate a Generic Environmental Impact Statement (GEIS) to assess the full scope of Cornell’s synthetic turf expansion, including cumulative impacts across multiple projects; ● Suspend further consideration of this project until: ○ Stormwater modeling is corrected to reflect DEC standards; ○ Independent PFAS testing results—currently underway—are made public and reviewed by the Town. The record as it stands is incomplete and cannot support responsible or lawful project approval. Respectfully submitted, Zero Waste Ithaca info@zerowasteithaca.org References: Zero Waste Ithaca. The Case Against Artificial Turf Expansion at Cornell: A Bibliography. Updated May 5, 2025. https://docs.google.com/document/d/1wZA9W7i-cU9rSOxzSTuGJit9pJtEM-s_4bfbmO26R -Q/edit?usp=sharing 1 From:bethany ojalehto mays <bethany.o.mays@gmail.com> Sent:Tuesday, May 6, 2025 3:45 PM To:Town Of Ithaca Planning Cc:Chris Balestra; Abby Homer Subject:Public comment submission RE: Game Farm Road **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 Chris, Abby, and Planning Board staff, I would like to submit a public comment re: the Game Farm Road project for the Planning Board's consideration at tonight's meeting. Kindly include this in the public record, if you may. I would also like to make a spoken comment at the meeting. Thank you. 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 1 RE: Game Farm Road Project Public comment (to be included in the public record) May 6, 2025 Dear Town Planning Board Members and Staff: On March 17, 2025, I presented evidence from the scientific literature and the applicant’s own materials that requires a positive declaration of environmental significance for the Game Farm Road Project.1 Many of those points are now underscored in a legal memo by Stephen Daly of Citizen Environmental Law PLLC on behalf of Ithaca Residents Acting for the Environment. Please attend closely to the recommendations outlined in that legal memo to ensure that the applicant’s representations about PFAS testing, stormwater filtration, and end-of-life recycling are executed in a binding fashion that ensures credibility, transparency, and mitigation of some harms from this petrochemical plastic installation. These must be preconditions for site plan approval. Lest you seek to dismiss concerns about PFAS testing once again, I have explained why it is necessary below (see Section A). In brief, there is a history of failed promises, faulty testing, and misleading definitions of “PFAS-free” products. You saw this firsthand when Cornell represented that their Meinig Fieldhouse turf products would be “PFAS-free” yet would also contain PVDF (a PFAS compound) and recycled tire crumb (known with certainty to contain PFAS). Below, I raise two additional concerns about your Board’s unexamined repetition of manufacturer and applicant claims that plastics are harmless, and your Board members’ claim that it is not their “purview” to accurately review the health and environmental impacts of artificial turf. Do Not Replicate Questionable Information from Manufacturers The Board issued a troubling replication of manufacturer/applicant claims in their FEAF: “Low density polyethylene is also used for food packaging, packing film, squeezable bottles, pipes/tubing, and medical/health care items. The application materials state that since polyethylene is made from a polymer that is stable at high temperatures, it is inert and is not associated with any known health effects, nor is it considered to be carcinogenic by nationals and world health agencies. The polyethylene Material Safety Data Sheet (MSDS) that is linked in the application supports these assertions.” 1 In that 21-page written public comment, I documented concerns about (1-3) Cornell’s claim that the turf field will be PFAS-free; (4) inadequate mitigation of microplastics contamination; (5) the Board’s failure to solicit independent expertise on a matter where they acknowledge they lack relevant expertise; and (6) the applicant’s misrepresentation of the terms of SEQR segmentation. I encourage you to review that comment again, because it was summarily and completely ignored during the Board’s March 18 environmental determination. 2 This FEAF statement appears to be derived from the applicant’s claims on March 4, 2025, that “Even if you ingest LDPE you can’t digest it - just as no exposure to polyethylene occurs when drinking from a water bottle made of polyethylene” (see screenshot below and recording at 3:08). These statements appear irreconcilable with the scientific literature. We know that people are exposed to nanoplastic particles when they drink from polyethylene water bottles. The average litre of bottled water contains almost a quarter of a million nanoplastic fragments (Qian et al., 2024). This is incompatible with the applicant’s claim that "no exposure to polyethylene occurs when drinking from a bottle made from polyethylene" (PE) – the very same bottles tested in this study. Alarmingly, those same researchers state that, “In particular, nanoplastics are believed to be more toxic since their smaller size renders them much more amenable, compared to microplastics, to enter the human body.” Nanoplastics, you will be aware, are precisely the particles that Cornell’s stormwater filtration system will not filter out. Cornell asserts that their filtration system will capture “detectable” microplastics while ignoring all microplastics smaller than 25 microns – not to mention airborne particles. We also know that nano- and micro-plastics enter human bodies, in direct contrast to the applicant’s claim that the plastic in their turf product can be “ingested” but not “digested,” by which they evidently mean the plastics cannot be taken up biologically. Yet polyethylene plastics are known to cross the blood-brain barrier and have been found in many human organs. The World Health Organization warns that the smallest fragments of microplastics (measuring less than 10 micrometres) are likely to be taken up biologically. Confirming that, polyethylene (the same plastic used in Cornell’s product) is the most prevalent polymer found in placentas (Garcia et al., 2024; see also Haederle, 2024) and human brains (Nihart et al., 2025), and is also prevalent in human breast milk (Saraluck et al., 2024). This is inconsistent with the applicant’s claim that microplastics can't be digested and/or taken up biologically. Incidentally, the claim that microplastics are “inert” appears meaningless. A bullet and a knife would both qualify as “inert” on this vacuous definition – that does not make them harmless. In any case, nano- and micro-plastics are known to act as vectors that accumulate and convey toxins in the environment (e.g., Sobhani et al., 2021). There is a growing body of evidence that nano- and micro-plastics are associated with a wide range of health risks (for just one example, see Xu et al., 2022), in contradiction to the Planning Board’s FEAF claim that they are “not associated with any known health effects.” I am frankly astonished that members of our Planning Board have repeated misinformation in their Full Environmental Assessment Form. This alone is a shocking indicator of how skewed these proceedings have been. It reveals how the Board has failed their duty to consider the best available scientific evidence in weighing the consequences of this project. It also underscores how severely the Board has failed to make good on their own commitment to secure outside expertise, a commitment that was applauded by the expert Dr. Genoa Warner, NJ Institute of Technology, Dept of Chemistry and Environmental Science, in her email correspondence with the Planning Board: 3 “It is great that you are looking for [an] objective third party to review this because so many communities rely exclusively on information from manufacturers.” (p. 12 of 213 in the Packet Information from the Town Planning Board Packet for the March 4, 2025 ) This is your Job. Do not Pretend that It’s Not. Members of this Board have sought to abdicate their responsibility for a careful scientific review of the health and environmental harms of artificial turf on grounds that this is “outside their purview,” “politicized,” “ideological,” or constituted “scapegoating” of the athletic community. For instance, in support of a negative declaration on March 4, Planning Board member Liz Bageant stated that, “Would I prefer that there be less plastic in the world? Definitely. But I don’t think that this project is the place to push for that.” No, this project is not the place to push for more or less anything. Instead, this project – and every project – is the place for the Planning Board to impartially review the best available scientific evidence and issue a credible environmental determination that takes into account concerns from the public and the scientific community, rather than deferring to the applicant. The Planning Board has so far failed to fulfill that job. It is not too late to correct the course. I fear for the children – human and nonhuman – who have to live with the consequences of this Planning Board’s failure to follow the scientific evidence. Al Gore is hardly a radical. But in a recent address, he pointed out that fossil fuel companies are losing their home markets of electricity generation and transportation, so “they’re telling Wall Street that they’re going to make up all of the expected lost revenue in their first two markets by tripling the production of plastics over the next 35 years.” He asks: “Is that realistic? Because we’ve already found – the scientists say – that some seabirds are manifesting symptoms like Alzheimer’s disease from the plastic particles in their brains and they found that it crosses the blood-brain barrier in humans, and the size of the amount has doubled just in the last decade. Do we really want to continue that? It’s crazy, but they are blocking action at both of these international forums and they’re blocking action in the deliberations of nation-states, even in states and provinces, and even at the local level. Anywhere in the world where there is an effort to pass legislation or regulations that reduces the burning of fossil fuels, they are there with their money, with their lobbyists, with their captive politicians, blocking it as best they can.” Here in Ithaca, I am not aware of any fossil fuel lobbyists blocking action. It is not “evil” fossil fuel executives who are pushing for destruction. As Hannah Arendt observed in another context: It is ordinary people who insist upon doing their jobs the way they have always done them – even when those jobs are causing catastrophe. It is ordinary athletes who are willing to leave future 4 generations of athletes with thousands of tons of toxic waste and carbon emissions in order to play for 8-12 years on the most convenient plastic field themselves. It is ordinary people who are not brave enough to ask questions of the status quo. It is ordinary people who refuse to speak up for science, ethics, and the change we need, and instead duck their heads and take cover under “the way we’ve always done things” or the idea that “this is someone else’s purview.” This is your purview. You are our neighbors, friends, former Cornell faculty, and people who say you care about science and this community. Why are you rejecting the evidence-based concerns of the public, rejecting the scientific data, and replicating biased information from the plastics industry in your environmental assessment form? Please rescind your negative declaration and initiate a GEIS. At the very least, please do not approve the site plan until the applicant fulfills conditions on independent and rigorous PFAS testing, correct and comprehensive stormwater modeling, and verified recycling plans as outlined in the legal memo from Citizen Environmental Law PLLC. Sincerely, bethany ojalehto mays, PhD Appendix A) To Dismiss PFAS Concerns is to Ignore the Evidence and Abdicate Your Responsibility The legal memo from Citizen Environmental Law PLLC should make it clear that your Board has so far abdicated responsibility by claiming that you can ignore the issue of PFAS in your review. According to your FEAF: “Because the product is PFAS-free (as will be confirmed in both phases by independent testing laboratory prior to the product’s delivery to the project site), information provided to the Planning Board about the effects of PFAS are not relevant to this project.” This statement is wholly unwarranted. First, it ignores the history of failed promises for PFAS-free turf, as repeatedly documented in public comments. That history reveals disputed notions of what a “PFAS-free” turf installation entails, with the manufacturers’ definitions evidently allowing for PFAS contamination. Each Ithaca Town Planning Board member must now be fully aware that Cornell made just such a claim on the interconnected Meinig Fieldhouse Project, where they (1) conceded that their product’s plastic blades would contain PVDF (a type of PFAS), which they incorrectly characterized as harmless before your Board; (2) confirmed that their product would contain tire-crumb infill, known without doubt to contain PFAS; and (3) yet simultaneously represented that their product would be PFAS-free. These three claims cannot all be true. Clearly, the applicant’s definition of a “PFAS-free” product in the case of the Meinig Fieldhouse allows for the presence of PFAS. Therefore, the applicant’s pledge for a “PFAS-free product” cannot be taken as assurance that the Board can ignore concerns about PFAS in their environmental review. 5 Recognizing these problems, the legal memo from Citizen’s Environmental Law PLLC urges you to require independent, credible testing that conforms to best practices prior to issuing site plan approval. Please do so. It would be an abdication of your responsibility to disregard threats to public health and environmental safety on the pretense of a PFAS-free turf installation promise. Issuing site plan approval in the absence of such testing would amount to approving an unbuildable project. There is no independent evidence to date that such a field exists. There is plenty of evidence that such promises have repeatedly failed, at great cost to the communities forced to bear the consequences. If the Planning Board grants final site plan approval absent testing to ensure that their own criteria are met, then they risk being locked into accepting whatever turf product Cornell says is possible. To repeat: There is absolutely no evidence that a PFAS-free turf product exists, and voluminous scientific evidence that such products do not exist (including, notably, the “research summary” submitted by Cornell’s own consultant.) Slide from the Applicant on the Game Farm Road Project: Peer-reviewed Sources on Nano- and Micro-plastics: Nihart, A.J., Garcia, M.A., El Hayek, E. et al. (2025). Bioaccumulation of microplastics in decedent human brains. Nat Med 31, 1114–1119. https://doi.org/10.1038/ 6 N. Qian, X. Gao, X. Lang, H. Deng, T.M. Bratu, Q. Chen, P. Stapleton, B. Yan, & W. Min (2024). Rapid single-particle chemical imaging of nanoplastics by SRS microscopy, Proc. Natl. Acad. Sci. U.S.A. 121 (3) e2300582121, https://doi.org/10.1073/pnas.2300582121. Saraluck A, Techarang T, Bunyapipat P, Boonchuwong K, Pullaput Y, Mordmuang A. (2024) Detection of Microplastics in Human Breast Milk and Its Association with Changes in Human Milk Bacterial Microbiota. J Clin Med. 2024 Jul 10;13(14):4029. doi: 10.3390/jcm13144029. PMID: 39064070; PMCID: PMC11277308. Marcus A Garcia, Rui Liu, Alex Nihart, Eliane El Hayek, Eliseo Castillo, Enrico R Barrozo, Melissa A Suter, Barry Bleske, Justin Scott, Kyle Forsythe, Jorge Gonzalez-Estrella, Kjersti M Aagaard, Matthew J Campen. (2024). Quantitation and identification of microplastics accumulation in human placental specimens using pyrolysis gas chromatography mass spectrometry, Toxicological Sciences, Volume 199, Issue 1, May 2024, Pages 81–88, https://doi.org/10.1093/toxsci/kfae021 Zahra Sobhani, Cheng Fang, Ravi Naidu, Mallavarapu Megharaj, (2021). Microplastics as a vector of toxic chemicals in soil: Enhanced uptake of perfluorooctane sulfonate and perfluorooctanoic acid by earthworms through sorption and reproductive toxicity. Environmental Technology & Innovation, Volume 22, 2021, 101476, ISSN 2352-1864, https://doi.org/10.1016/j.eti.2021.101476. Jun-Li Xu, Xiaohui Lin, Jing Jing Wang, Aoife A. Gowen (2022). A review of potential human health impacts of micro- and nanoplastics exposure. Science of The Total Environment, Volume 851, Part 1, 2022, 158111, ISSN 0048-9697, https://doi.org/10.1016/j.scitotenv.2022.158111. Press coverage of microplastics research findings: Haederle, M (February 2024). Microplastics in Every Human Placenta, New UNM Health Sciences Research Discovers. UNM Health Sciences. Gerretsen, I. (March 2024). Microplastics are everywhere: Is it possible to reduce our exposure? BBC. Town Planning Board Spoken Public Comment 5/6/2025 bethany ojalehto mays SPOKEN COMMENT I urge you to implement the preconditions for site plan approval outlined in the legal memo from Citizen Environmental Law PLLC. They will ensure that promises about PFAS testing, stormwater filtration, and recycling are executed in a binding fashion that ensures accountability and transparency. It is the bare minimum your Board can do in the absence of an EIS. If you issue site plan approval in the absence of those conditions, you will approve an unbuildable project. There is no evidence to date that a PFAS-free turf exists. Likewise, all evidence indicates that plastics recycling is an abject failure. We don’t need hope-based decision-making. We need evidence-based decision-making. That’s your job. On that note, I am troubled by your replication of industry claims. In your FEAF, you stated that the low density polyethylene used for this product is: “inert and is not associated with any known health effects, nor is it considered to be carcinogenic.” This appears to be derived from the applicant’s claims that “Even if you ingest LDPE you can’t digest it - just as no exposure to polyethylene occurs when drinking from a water bottle made of polyethylene.” Those statements are irreconcilable with the scientific literature. First, you are definitely exposed when drinking from plastic water bottles including polyethylene ones. The average litre of bottled water contains almost a quarter of a million nanoplastic fragments (Qian et al., 2024). Second, those nanoplastics are definitely taken up biologically. They cross the blood-brain barrier. Polyethylene is the most prevalent polymer found in placentas and human brains, and it’s also prevalent in human breast milk. Your FEAF and the applicant are both wrong: microplastics can be taken up biologically, and there is a growing body of evidence that they’re associated with a wide range of health risks. Moreover, researchers say that, “nanoplastics are believed to be more toxic since their smaller size renders them much more amenable…to enter the human body.” Nanoplastics are precisely the particles that Cornell’s filtration system will not capture. You all know that. The misinformation in your Environmental Assessment Form is an indicator of how skewed these proceedings have been. It reveals how the Board has failed to consider the scientific evidence, and failed to make good on your own earlier commitment to secure outside expertise. Finally, this is your job. Board members have abdicated responsibility for environmental review on grounds that this is “outside their purview,” “politicized,” or constitutes “scapegoating” of the athletic community. That is not true. Other Planning Boards are saying no to artificial turf, and/or requiring full environmental reviews. This is your purview. Until we have adequate legislation at the state and local level, we rely on YOU to keep our communities safe. In the absence of legislation, we rely on you to adapt your decision-making to the latest, most reliable scientific evidence for our protection. Don’t let us down. 1 From:ear1421@gmail.com Sent:Tuesday, May 6, 2025 3:25 PM To:Town Of Ithaca Planning Subject:NYC Now Has 286 Plastic Turf Fields—Is Ithaca Next? **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 evening. My name is Emily Jernigan, and I’m speaking as a mother of an infant and as a member of Zero Waste Ithaca. I want to draw your attention to a recent report from Columbia Journalism School News Service that highlights what’s happening downstate in New York City. As of today, NYC manages 286 synthetic turf fields, with more in planning or construction. These numbers come directly from the city’s own Open Data portal. This is not just an NYC problem—it’s a cautionary tale. What starts in large institutions like Cornell often sets the tone for municipalities across the state. Cornell already has multiple synthetic turf fields, and each new one sends a message: plastic turf is normal, acceptable, even necessary. But it’s not. Synthetic turf contains toxic chemicals like PFAS, known as “forever chemicals,” which have been linked to cancer, immune disruption, and developmental harm. It overheats in summer sun, contributes to microplastic pollution, and creates recurring costs and disposal burdens every 8–10 years. And yet, the public is too often excluded from the decision-making until it's too late. In NYC, parents found out only after construction began. One mother FOILed for chemical safety data on the turf her toddler plays on—months later, she still hasn’t received answers. The turf is already in. Her child is already walking on it. That’s not informed consent. That’s a betrayal of public trust. Ithaca has a choice. You can either follow this path—or break from it. Planning boards are not just rubber stamps. You are stewards of public health and environmental integrity. I urge you to consider the long- term implications of enabling synthetic turf expansion here. Please don’t let Ithaca become the next data point in a growing statewide plastic turf crisis. Thank you. References: https://columbianewsservice.com/2025/04/17/city-increasingly-swaps-soil-for-synthetic-as-green- space-gets-less-green/ https://data.cityofnewyork.us/Recreation/Synthetic-Turf-Fields/weh8-3ujf/about_data 1 From:Cheryl Botts <espanolconcheri@gmail.com> Sent:Tuesday, May 6, 2025 1:17 PM To:Town Of Ithaca Planning Subject:Please accept for this eve meeting **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 Hello I am sorry if I missed a deadline but here is an article to please bring up for backing the argument for why Ripping up grass and replacing with artificial isn’t a good idea. Let’s be a town that does the right thing for future generations!! Please!!! https://columbianewsservice.com/2025/04/17/city-increasingly-swaps-soil-for-synthetic-as-green- space-gets-less-green/ Thanks so much! Cheryl Botts Espanol con Cheri (607) 277-1620 espanolconcheri@gmail.com Retired Spanish Teacher Substitute teacher, Ithaca City Schools Cheryl Botts Espanol con Cheri (607) 277-1620 espanolconcheri@gmail.com Spanish Teacher Elmira City School District & private tutoring