WRITTEN PUBLIC
COMMENTS RECEIVED
response to previous City and State
encouragement during drought years, particularly
after 2015 when State law required allowances for
water-saving landscaping, including synthetic
turf.
Artificial turf has provided homeowners with the
ability to conserve water, reduce maintenance
costs, and comply with water restrictions.
Removing these installations now places an
unexpected financial burden on those who acted
in good faith and in compliance with City
ordinances at the time.
Importance of Grandfathering Existing Properties
Grandfathering, or allowing pre-existing installations
to remain under old regulations, is a common legal
and civic practice. This approach recognizes the
investments and decisions made under prior legal
frameworks and provides fairness to affected
property owners. Here are examples and concepts
for your consideration:
The City's Current Proposal
The current draft ordinance proposes a 15-year
period for existing synthetic turf permit holders to
remove their artificial turf. Residents may also
request extensions from the Council if more time
is needed due to unique hardships
While this is a step in the right direction, offering
a true “grandfather clause” — allowing artificial
turf installed before the ban to remain indefinitely,
or until property transfers or major modification
— would provide even greater protection and
equity for current homeowners.
Request for Council Consideration
Grandfathering for Prior Installations: Please
consider a provision that allows existing artificial
turf installations, permitted under previous City
rules, to remain for their useful lifespan, or until
property ownership changes or major
modification. This approach would follow
standard legal and policy practices, respecting
the investments of Beverly Hills residents.
Thank you for your attention to this matter and your
service to our community. I urge the Council to adopt
a fair, sensible solution that protects both the
environment and the property rights of current
residents for the reasons of:
Widespread Resident Approval: Many
homeowners appreciate artificial turf for its
water-saving benefits, almost no maintenance,
and year-round appearance. Which is vastly
superior aesthetically looking to water drought
plants.
Lana Butler
Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
Beverly Hills City Council - 15 July 2025, Item #E1
Proposed Artificial Grass/Synthetic Turf Ordinance
Mayor Nazarian, Vice Mayor Mirisch, Councilmembers Friedman, Corman and Wells:
Thank you for the opportunity to submit comments on this item today on behalf of Safe Healthy Playing Fields, Inc. (SHPFI). SHPFI is an all-volunteer 501-c-3 non-profit organization. We are committed to educating communities, policymakers and elected officials about the health, safety and financial realities of plastic fields versus grass fields and other synthetic surfaces for their parks and schools, homes and businesses. Our constituency ranges from concerned individuals to community and civic organizations, legal, healthcare and science professionals, municipal leaders and state legislators.
SHPFI urges the city of Beverly Hills to ban the use of synthetic turf/artificial grass for all residential use as well as on city owned and leased land.
By allowing synthetic turf in side and back yards, or any area of Beverly hills, you are allowing:
● Neighbors to pollute neighbors
● Continuation of synthetic turf’s contribution to climate change ● Increased risk of wildfire and subsequent landslides
● Increased human and environmental health risks
● Loss of biodiversity
● Increasing plastic, micro- and nano plastic waste
● Ongoing contamination of surface and groundwater, waterways and the ocean …for centuries to come
You would also be putting the cart before the horse due to currently evolving regulation of this highly toxic product by CA Department of Toxic Substances Control1 and CalFire’s evaluation of use of this product in wildfire risk zones (rulemaking for Zone Zero by 31 Dec 2025).2 Decisions made by one or both of these regulatory authorities could result in additional staff time going back to the drawing board on an update of the city’s proposed ordinance. 2 CalFire. Defensible Space - Zones 0, 1, and 2. Board of Forestry and Fire Protection. https://bof.fire.ca.gov/projects-and-programs/defensible-space-zones-0-1-2/ 1 CA DTSC, Safer Consumer Products Program (27 Aug 2027). Chemicals of Concern in Artificial Turf. https://calsafer.dtsc.ca.gov/cms/commentpackage/?rid=12775 The synthetic turf industry is well aware of the increasing number of states banning their product and aware of regulation in CA. This is why this $6.5 billion industry has spends $36,000 per quarter on lobbying efforts in CA alone. That’s why they are scrambling for contracts with entire cities and school districts; why they are sending in letters and speaking in public comments.
They would love nothing more than to rush you to a decision ahead of full regulation. They have a product to sell, and lobbying efforts to support.
The science on the human and environmental health impacts of plastics and synthetic turf has progressed well beyond what was known when the city created its ordinance in 2015. Allowing its use in back and side yards perpetuates widespread pollution. It does not prevent microplastics created from synthetic turf blades from lofting into the air, carrying for miles and relofting over and over, releasing its toxic payload of chemicals to air, water and soil, acting as a vector for other toxic chemicals and bacteria, and contaminating our food chain.
Synthetic Turf is a Petrochemical Plastic Product:
Made of the same material as plastic straws and bags, synthetic turf is a fossil fuel based petrochemical product, as are 99% of plastics. The plastic blades are most often made of polyethylene, the most globally produced and discarded plastic. The backing may be made from latex, polyurethane or polyvinyl chloride.
There are over 16,000 known chemicals found in plastics. Of the known chemicals, 4,200 are considered “highly hazardous” to human and environmental health. Of these 4,200 chemicals, only 980 have been regulated by any global agency. Per- and polyfluoroalkyl substances (PFAS) are amongst the 15 categories of chemicals of concern in plastics.Less than 1% of chemicals in plastics can be considered non-hazardous.3 Additional chemicals of concern in are expected to be added to the DTSC regulation of synthetic turf.1
Plastic as Agent of Climate Change
‘This is a climate damn emergency’
Gov. Gavin Newsom
The Lawrence Berkeley National Laboratory released a report in April 2024 finding that the greenhouse emissions from plastics are four times those emitted by the aviation industry.4
4 Nihan, K, Khanna, N, Shah, N (Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence Berkeley National Laboratory.
https://energyanalysis.lbl.gov/publications/climate-impact-primary-plastic 3 LaMotte, S (14 Mar 2024). Toxic plastic chemicals number in the thousands, most are unregulated, report finds. CNN.com.
https://www.cnn.com/2024/03/14/health/toxic-unregulated-chemicals-report-wellness?cid=ios_app
The overheating of densely crowded and overbuilt urban centers, points to the desperate and unmet need of open natural green spaces if the effects of climate change are to be mitigated.5 Synthetic turf can readily become much hotter than asphalt, reaching temperatures of 1600F to 1800F (regardless of infill type; higher temperatures when a shock pad is placed under the plastic carpet) and have exceeded 222.8oF (106oC).6 Thermal burns on plastic turf have even required hospitalization.
At a surface temperature of 118°F a first-degree thermal burn occurs in 15 minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.
7 Synthetic turf off gasses methane and ethylene8 in ever increasing amounts:
● Methane traps 90% more heat than carbon dioxide.9
9 Climate Reality Project (2020). “REPOWER AMERICA®: Methane Stinks: Why Natural Gas is Bad News For The Planet.”
https://www.climaterealityproject.org/blog/methane-stinks-why-natural-gas-bad-news-planet?_ga=2.52526 049.897177029.1647384251-251106713.1647384251
8 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic in the Environment.” PlosOne 13(8): e0200574.
https://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0200574&type=printable 7 Moritz AR, Henriques FC Jr (1947). Original source. “Studies of thermal injury II: The relative importance of time and surface temperature in the causation of cutaneous burns.” Am J Pathol.; 23:
915-941.
http://www.antiscald.com/index.php?route=information/information&information_id=15 6 Power, J (14 May 2021). “Fake grass may be greener, but much hotter and less friendly to environment.” The Sydney Morning Herald.
https://www.smh.com.au/national/nsw/fake-grass-may-be-greener-but-much-hotter-and-less-frie ndly-to-environment-20210312-p57a95.html
5 Liu, Z, Zahn, W, Bechtel, B et al (29 Sep 2022). “Surface warming in global cities is substantially more rapid than in rural background areas.” Nature Communications, Earth & Environment; (3), 219. https://www.nature.com/articles/s43247-022-00539-x
● Methane is 21 times more potent than carbon dioxide.
● Land based plastics produce 2 times more methane and 76 times more ethylene than plastics in waterways and oceans.41
● Each standard-size plastic field produces GHG emissions of 527 tons of CO2e per ten-year use period.10 (should be set up as a sentence like the others) ● Heat islands extend beyond the footprint of the plastic carpet, impacting the surrounding community.
● Synthetic turf playing fields create heat islands that are visible from satellites in space.
The resulting impact on climate change from plastics, microplastics11 and synthetic turf are contributing factors to increased flood risk and toxic runoff12; toxic exposures during wildfires13,14 , and escalating insurance costs.15,16,17
17 Capani, C (7 May 2024). “Aviva issues flood risk warning as residents turn to artificial lawns.” Insurance Times; United Kingdom.
https://www.insurancetimes.co.uk/news/aviva-issues-flood-risk-warning-as-residents-turn-to-artificial-lawn s/1451833.article
16 Sherriff, L (18 Mar 2024). “Climate change is fuelling the US insurance problem.” British Broadcasting Corp.
https://www.bbc.com/future/article/20240311-why-climate-change-is-making-the-us-uninsurable
15 Mandel, A, Battiston, S, Monasterolo, I. (5 Feb 2025). “Mapping global financial risks under climate change. Nature, Climate Change.
https://doi.org/10.1038/s41558-025-02244-x
14 Staff writer (17 Jan 2025). “Plastic Chemicals in Wildfire Smoke and How to Protect Yourself.” Plastic Soup Coalition.
https://www.plasticpollutioncoalition.org/blog/2025/1/17/plastic-chemicals-in-wildfire-smoke-and-how-to-pr otect-yourself
13 Schlanger, Z (15 Jan 2025). “What Happens When a Plastic City Burns.” The Atlantic. https://www.theatlantic.com/science/archive/2025/01/los-angeles-fire-smoke-plastic-toxic/681318/ 12 Simpson, TJ, Francis, RA (Aug 2021). “Artificial lawns exhibit increased runoff and decreased water retention compared to living lawns following controlled rainfall experiments.” Urban Forestry & Urban Greening; (63), 127232
https://www.sciencedirect.com/science/article/abs/pii/S1618866721002570 11 Sunil, S, Bhagwat, G, Vincent, SGT, Palanisami, T (10 Oct 2024). “Microplastics and climate change:
the global impacts of a tiny driver.” Science of The Total Environment; (946),174160. https://www.sciencedirect.com/science/article/abs/pii/S0048969724043080 10 Magnusson, Simon, Mácsik, Josef (July 2017). “Analysis of Energy Use and Emissions of Greenhouse Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf.” Resources, Conservation and Recycling: (122), Pages 362-372.
https://doi.org/10.1016/j.resconrec.2017.03.
Combustible: not ember/fire resistant
Despite industry claims, synthetic turf poses significant risks in wildfires. Claims of meeting ASTM standards18 are meaningless. Such tests are conducted in controlled laboratory settings and do not even approximate the realities of wildfires. Testing has shown synthetic turf to be easily flammable.19 Research from Australia reports:
“Glowing embers, as are commonly blown in front of an advancing bushfire, have a temperature of around 700-800oC, and the flame of a burning leaf has a temperature of around 700oC. Strips of polyethylene can be ignited with the flame of a match which has a temperature of around 700oC.”20.
“Over the past two decades, we saw a 250 percent increase in fire speed across the West that I don’t see slowing down anytime soon.” Fire ecologist, Jennifer Balch.21 (Q:
not clear—does this refer to Australian west or US?)
Antimony, hindered amine light stabilizers (HALS), and benzotriozoles are examples of chemical additives utilized by the synthetic turf industry to make their products less flammable. These additives have significant long term ramifications for human and environmental health, long after flames are put out.
Burned synthetic turf outside of Zone 0, Altadena, 2025 21 Deng, J (11 Jan 2025). “The Dichotomy of a Deadly Paradise—How Urban Sprawl and Climate Change Fuel LA’s Fires.” Inside Climate News.
https://insideclimatenews.org/news/11012025/los-angeles-wildfires-in-altadena-and-pacific-palisades/ 20 Horticulture Innovation Australia Limited (Apr 2020). “Living Turf Fire Benefits Study - Literature review.” GHD Australia.
https://www.horticulture.com.au/globalassets/hort-innovation/resource-assets/tu17008-literature-review-liv ing-turf-fire-benefits-study.pdf
19 Kukfisz, B (2018). “The Degree of Flammability for an Artificial Grass Surface System.” The Main School of Fire Service, Faculty of Fire Safety Engineering, Warsaw, Poland. https://doi.org/10.1051/e3sconf/20184500038
18 ASTM international; testing standards.
https://www.astm.org/
Insurers care about the granularity of fire hazard maps - wildfire does not. 15 year phase out is EXCESSIVE
To base an ordinance on a 15 year prorated warranty for landscape artificial turf makes no sense. The three manufacturers who offer landscape turf are:
● Pregras (Costco) - 10 yr. warranty. 100% yrs. 0-4.
● Synlawn (Home Depot; Lowes) - 15 yr. warranty. 100% yrs. 0-8. ● TenCate (the company lobbying the city) - 15 yr. warranty. 100% yrs. 0-10.
Warranties are written to protect the manufacturer, not the homeowner. The warranties are tied to loss of fibers attributable to ultraviolet degradation as determined by tensile strength and/or percentage loss in plastic blade height. Further, should a homeowner or business opt for synthetic turf not specified for landscaping, warranties are much shorter (8 to 10 year range). All warranties can be voided in the absence of documentation that maintenance guidelines were strictly adhered to.
We urge the City of I, Beverly Hills to make this overdue pivot away from plastic With an abundance of native plants and drought tolerant grasses (being grown in Ramona, Coachella Valley, Stockton, CA and elsewhere) - it’s time to ban this toxic product for the health and safety of residents and the environmen
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
TenCate doesn’t want you to vote for synthetic turf based on aesthetics…they know what aging plastic turf looks like:
Microplastic blade loss:
While we commend the Planning Commissioners for initiating this important discussion about the impact of artificial grass on the environment, an outright ban will lead to loss of small businesses and jobs that were encouraged to be created during our drought crisis. Our union will lose thousands of jobs throughout California if such ban is passed throughout the state.
Rather than banning an entire industry, implementation of thoughtful regulation of eliminating harmful materials and creating an industry standard should be considered. In fact, the current ordinance already bans PFAS and infill materials in the City of Beverly Hills. Furthermore, we are in a process of passing a statewide regulation in the CA State Legislature. We urge you to delay any permanent ordinance change until the state implements their regulations that will have an impact on your city’s ordinance.
We look forward to speaking with you as you prepare to hear this issue in your future City Council meeting.
I can be reached at [email protected] and/or 818-205-8513.
Thank you.
Political Director
1155 Corporate Center Drive, Monterey Park, CA 91754 TEL: (626) 584-9925 FAX: (626) 584-1949 July 14, 2025
The Honorable Sharona R. Nazarian Syd
Members of the Beverly Hills City Council
455 N Rexford Drive
Beverly Hills, CA 90210
Dear Mayor Nazarian and Members of the Beverly Hills City Council, We are writing on behalf of the short term rental operators in the City of Beverly Hills who have been responsibly operating in the city and respectfully oppose the proposal to prohibit single family properties and multifamily residences from being leased for fewer than 12 consecutive months. Hosts in Beverly Hills typically operate only one rental, contrary to the claims that the short-term rental market is dominated by large commercial entities. We welcome reasonable and effective regulations that balance the benefits of hosting with community needs. The local host community is eager to work with you on sensible measures that protect the benefits from home sharing while addressing local challenges.
We are deeply concerned that this ordinance paints an overly broad brush and risks eliminating an important source of supplemental income for longtime residents, including seniors and caregivers. As expressed in public testimony, some of our neighbors depend on short-term rental (STR) income to preserve historic homes and provide for their families, often while living onsite.
These are not party houses or absentee landlords. These are responsible residents who care about their community such as Debra Blum, who uses income from renting her guesthouse to fund the maintenance of a historic landmark that otherwise would be at risk of deterioration or demolition.
The ordinance also relies heavily on speculative or inconsistent claims about the link between STRs and housing affordability. As SF Gate noted, “For years, the city of Beverly Hills (population 31,000, with a median home listing price of $5 million) has pushed back on statewide mandates for affordable housing.” It is difficult to accept the argument that banning short-term rentals will meaningfully improve affordability in a city where home prices have long excluded working and middle class families. A $5 million estate will not become affordable simply because a guesthouse can no longer be rented out for two weeks at a time, but it will have a negative impact on a current Beverly Hills homeowner. This is not an effective housing strategy. This will hurt your constituents by pushing them out while doing nothing to address the underlying affordability crisis.
In the recently published Long Term Solutions to Short-Term Rentals 2024-2025 report, the Orange County Grand Jury concluded that “STRs should not be considered a significant factor in the availability of affordable housing in Orange County cities with STRs… In many areas of the County, STRs are luxury or large-scale homes. It is extremely unlikely that such homes could or would be easily converted into affordable housing or demolished to create multiple affordable dwellings.”
Rather than adopt a blanket prohibition, we urge the City to pursue reasonable regulations, which include grandfathering existing permits and exemptions for owner occupied or historic properties. This would go further in addressing the City’s concerns while avoiding undue harm to residents.
Finally, short and mid term rentals fulfill a real and growing need in our city. Take the LA wildfires for example, where Airbnb.org was able leverage Airbnb’s host community to provide free emergency housing to more than 20,000 people impacted in our area –including first responders. This city has already recognized the value of short term rentals by sensibly suspending regulations to house neighbors displaced by the Palisades and Eaton fires, a clear sign that thoughtful, flexible STR regulations are possible. Families seeking temporary housing due to medical treatment, business travel, relocation, or home repairs also rely on these rentals.
Removing this option could take away critical infrastructure and hurt the city’s economy and hospitality reputation.
We urge you not to adopt the ordinance as proposed. Instead, we respectfully ask the City Council to consider a balanced framework that allows responsible STR operators to continue contributing to the fabric of Beverly Hills.
Thank you for your attention to this important matter.
Sincerely,
California Short Term Rental Association (CalSTRA)
From: Beverly Hills Long Range Planning
To: City Clerk
Cc: Michael Forbes; Masa Alkire; Chloe Chen
Subject: FW: Short Term Rental Ordinance Review - City Council 7/15/2025 Meeting Date: Tuesday, July 15, 2025 8:30:27 AM
Attachments: image001.png
Hello,
Please refer to the public comment below regarding FS 3 (Short Term Rental Ordinance Review) on tonight’s agenda.
Best,
Patrick Achis
Associate Planner
Long Range Planning
Community Development
310-285-1129
[email protected]
NOTE: Planning applications and project resubmittals are currently accepted via email. However, planning applications and project resubmittals are not considered received by the City until such submittal is acknowledged by a Planning Division staff member. If you have questions regarding the status of your planning application, please call 310-285-1000 and ask to speak to a planner. If you have questions about the status of your project resubmittal, please reach out to your assigned planner directly.
From: michael hartounian
Sent: Monday, July 14, 2025 6:00 PM
To: Chloe Chen <[email protected]>
Cc: Masa Alkire <[email protected]>; Michael Forbes <[email protected]>; Beverly Hills Long Range Planning <[email protected]>
Subject: Re: Short Term Rental Ordinance Review - City Council 7/15/2025 Meeting People who rent apartments as a vacation apartment, or simply a place to stay (i.e transient use) for cheap because of rent control should be excluded the protections afforded permanently full time residents.
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