CleanPowerSF Sfpuc Commission
December 9, 2025

OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.

525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488

San Francisco Public Utilities Commission
Correspondence Log
November 3, 2025 through December 2, 2025

Date Received From Subject
11/3/2025 Robert Hall Request for Updated Policy and Monitoring of Synthetic Turf Drainage (email + 2 attachments)
11/3/2025 Robert Hall Request for Coastal Zone Review of Synthetic Turf Expansion Adjacent to Groundwater Recharge Areas
11/3/2025 Robert Hall Request for SFE Coordination on PFAS and Microplastics Monitoring from Synthetic Turf Installations
11/4/2025 Sandra Lee Messer Survey follow up comment
11/7/2025 Mayor Daniel Lurie Comment Letter – Draft Scientific Basis Report Supplement for the Tuolumne River Voluntary
Agreement
11/13/2025 Francisco Da Costa Please circulate this letter - linked to Joe King, Conrad King, Adolfo Padilla
11/13/2025 Lourdes Enriquez November 20, 2025 BAWSCA Board of Directors Meeting Agenda (email + attachment)
11/15/2025 Robert Hall Ask the Historic Preservation Commission to Agendize Crocker Amazon
11/19/2025 Alex Lantsberg Fw: CCA Alliance Letter for Today's CC Power Board Meeting (email + attachment)
11/23/2025 Francisco Da Costa The San Francisco Public Utilities Commission must resolve this case - stop kicking the can down the street.

OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.

525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488

San Francisco Public Utilities Commission
Correspondence Log
November 3, 2025 through December 2, 2025

Date Received From Subject
11/25/2025 Dennis Williams, Jr. Introduction – Local Developer & Community Partnership for SEP7
11/25/2025 Dennis Williams, Jr. Local inclusion opportunities 11/26/2025 Eileen Boken Coalition for San Francisco Neighborhoods Resolution re Transferring AWSS from SFPUC Back to SFFD (email +
attachment)
12/1/2025 Dave Warner Affordability is a hot topic at BAWSACA (email + attachment)
12/2/2025 Peter Drekmeier Letter to Commissioners (email + attachment)

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Robert Hall
To: Commission; Capone, Kelley; Kehoe, Paula; Kortkamp, Ken; Bloom, Sarah E; Ortiz, Joseph; [email protected]; Andersen, Eric (REC); Lyles, Christopher; Johnson, Nicholas M Subject: Request for Updated Policy and Monitoring of Synthetic Turf Drainage & Groundwater Protection Date: Monday, November 3, 2025 3:03:56 PM
Attachments: Groundwater protection letter.pdf
Draft memo on SF policy synthetic turf drainage and GW quality protection 190919.pdf Dear SFPUC Commissioners and staff,
I am requesting that the Commission direct the Water Resources and Wastewater divisions to finalize the synthetic turf groundwater protection policy, complete the analysis of collected monitoring data, and include PFAS and microplastics testing in all future evaluations.

Because synthetic turf fields in San Francisco are located directly above portions of the Westside Groundwater Basin, and because installation and replacement of turf fields continue to proceed in the absence of completed guidance, this review is urgently needed to protect drinking water reliability and public trust.

Please see the full letter below, which I am also sharing with the Recreation and Park Department and San Francisco Environment Department to support coordinated policy alignment.

Thank you for your work and stewardship.

Sincerely,
Bob Hall
Keep Crocker Real
Please direct Water Resources Division to finalize the policy, complete analysis of past and current sampling, and incorporate PFAS and microplastics monitoring Re: Request for Updated Policy and Sampling Plan for Synthetic Turf Field Drainage and Groundwater Protection
I am writing to request that the San Francisco Public Utilities Commission (SFPUC) complete and release an updated policy governing stormwater drainage from synthetic turf athletic fields and their potential impacts to groundwater, building upon the Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection dated September 19, 2019.

The 2019 draft review noted that, despite widespread use of synthetic turf systems in the City, past monitoring data were not fully interpreted and consensus policy remains unresolved, especially concerning infiltration in the Westside Groundwater Basin.

Now, with additional turf installations proposed, including large expansion at Crocker Amazon Park, it is critical that SFPUC complete this analysis before further synthetic turf construction proceeds.

Summary of Past Monitoring Findings (2010–2012)
SFPUC sampling at South Sunset Playground and Garfield Square Park found:

Dissolved iron and manganese exceeding secondary drinking water standards during early-season rainfall.

Bis-(2-ethylhexyl)-phthalate, a plasticizer from synthetic rubber infill, above its 4 µg/L MCL in multiple events.

Dissolved copper exceeding screening levels for groundwater and surface water.

These exceedances occurred four-plus years after installation, indicating ongoing material breakdown and leaching, not temporary startup conditions.

Recent Findings and Data Gaps
Stormwater sampling at Beach Chalet in 2024 has not yet been publicly interpreted against groundwater protection criteria, and 2025 internal discussions referenced concern regarding chromium levels. This indicates the need for updated analysis.

Need to Evaluate PFAS and Microplastics
Since the 2010–2012 sampling program, research has increasingly identified PFAS (per- and polyfluoroalkyl substances) and microplastics as contaminants associated with synthetic turf fibers, infill, and backing materials. PFAS are now subject to enforceable U.S. EPA drinking water standards, and microplastics have been documented in Bay and watershed stormwater pathways.

Because the City’s synthetic turf fields function as exposed plastic surfaces that degrade under UV, abrasion, and weathering, it is both scientifically and regulatorily appropriate that the next round of evaluation:

Test stormwater drainage for PFAS compounds, including PFOS, PFOA, PFHxS, PFNA, and polymeric PFAS used in plastic turf coatings; and
Quantify microplastic particle shedding, including infill granules and synthetic blade fragments.

Monitoring these contaminants is essential for groundwater protection planning.

Requests
I respectfully request that SFPUC:

1. Finalize and publicly release a synthetic turf groundwater protection policy;

2. Complete and publish interpretation of the 2010–2012 monitoring data;

3. Analyze and release results from 2024–2025 Beach Chalet sampling;

4. Include PFAS and microplastics sampling and reporting in all future synthetic turf drainage evaluations;

5. Establish ongoing seasonal first-flush monitoring for synthetic turf fields;

6. Disclose leaching profiles of alternative turf and infill materials; and

7. Enact a pause on new or expanded synthetic turf installations, including the proposed expansion at Crocker Amazon Park, which is adjacent to and hydrologically connected to the SFPUC Amazon Reservoir and groundwater recharge zone, until updated policy and monitoring frameworks are in place.

Conclusion
SFPUC’s stewardship of the Westside Groundwater Basin is critical to San Francisco’s long- term water resiliency. Finalizing this policy now will provide clarity for City agencies, ensure environmental health protections, and maintain public confidence in groundwater safeguarding.

Thank you for your consideration.

Sincerely,
Bob Hall
Keep Crocker Real
Re: Request for Updated Policy and Sampling Plan for Synthetic Turf Field Drainage and Groundwater

Protection

I am writing to request that the San Francisco Public Utilities Commission (SFPUC) complete and release

an

updated

policy

governing

stormwater

drainage

from

synthetic

turf

athletic

fields

and

their

potential

impacts

to

groundwater,

building

upon

the

Draft

Review

of

San

Francisco

Policies

Related

to

Synthetic

Turf

Field

Drainage

and

Groundwater

Quality

Protection

dated

September

19,

2019.

The 2019 draft review noted that, despite widespread use of synthetic turf systems in the City, past

monitoring

data

were

not

fully

interpreted

and

consensus

policy

remains

unresolved,

especially

concerning

infiltration

in

the

Westside

Groundwater

Basin.

Now, with additional turf installations proposed, including large expansion at Crocker Amazon Park,

it

is

critical

that

SFPUC

complete

this

analysis

before

further

synthetic

turf

construction

proceeds.

Summary of Past Monitoring Findings (2010–2012)
SFPUC sampling at South Sunset Playground and Garfield Square Park found:
● Dissolved iron and manganese exceeding secondary drinking water standards during early-season

rainfall.
● Bis-(2-ethylhexyl)-phthalate, a plasticizer from synthetic rubber infill, above its 4 µg/L MCL

in

multiple

events.
● Dissolved copper exceeding screening levels for groundwater and surface water.

These exceedances occurred four-plus years after installation, indicating ongoing material breakdown

and

leaching,

not

temporary

startup

conditions.

Recent Findings and Data Gaps
Stormwater sampling at Beach Chalet in 2024 has not yet been publicly interpreted against groundwater

protection

criteria,

and

2025

internal

discussions

referenced

concern

regarding

chromium

levels.

This

indicates

the

need

for

updated

analysis.

Need to Evaluate PFAS and Microplastics
Since the 2010–2012 sampling program, research has increasingly identified PFAS (per- and polyfluoroalkyl

substances)

and

microplastics

as

contaminants

associated

with

synthetic

turf

fibers,

infill,

and

backing

materials.

PFAS

are

now

subject

to

enforceable

U.S.

EPA

drinking

water

standards, and microplastics have been documented in Bay and watershed stormwater pathways.

Because the City’s synthetic turf fields function as exposed plastic surfaces that degrade under UV,

abrasion,

and

weathering,

it

is

both

scientifically

and

regulatorily

appropriate

that

the

next

round

of

evaluation:

● Test stormwater drainage for PFAS compounds, including PFOS, PFOA, PFHxS, PFNA, and polymeric

PFAS

used

in

plastic

turf

coatings;

and
● Quantify microplastic particle shedding, including infill granules and synthetic blade fragments.

Monitoring these contaminants is essential for groundwater protection planning.

Requests
I respectfully request that SFPUC:

1. Finalize and publicly release a synthetic turf groundwater protection policy; 2. Complete and publish interpretation of the 2010–2012 monitoring data; 3. Analyze and release results from 2024–2025 Beach Chalet sampling; 4. Include PFAS and microplastics sampling and reporting in all future synthetic turf drainage

evaluations;

5. Establish ongoing seasonal first-flush monitoring for synthetic turf fields; 6. Disclose leaching profiles of alternative turf and infill materials; and 7. Enact a pause on new or expanded synthetic turf installations, including the proposed expansion

at

Crocker

Amazon

Park,

which

is

adjacent

to

and

hydrologically

connected

to

the

SFPUC

Amazon

Reservoir

and

groundwater

recharge

zone,

until

updated

policy

and

monitoring

frameworks

are

in

place.

Conclusion
SFPUC’s stewardship of the Westside Groundwater Basin is critical to San Francisco’s long-term water

resiliency.

Finalizing

this

policy

now

will

provide

clarity

for

City

agencies,

ensure

environmental

health

protections,

and

maintain

public

confidence

in

groundwater

safeguarding.

Thank you for your consideration.

Sincerely,
Bob Hall
Keep Crocker Real
Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

1 DRAFT TECHNICAL MEMORANDUM
Date: September 19, 2019 (with minor edits 9/23/19)
To: Kelley Capone, Groundwater Program Manager/SFPUC Water Resources Division (WRD)
Copies: Paula Kehoe/WRD, Ken Kortkamp/WWE, Sarah Bloom/WWE, Julie Ortiz/WRD, June Weintraub/SFDPH, Eric Andersen/SFRPD, Chris Lyles/WRD From: Nick Johnson, Water Operations Analyst/WRD
Subject: Draft Review of San Francisc o policies related to synthetic turf field drainage and groundwater quality protection
Table 1 lists eleven synthetic turf athletic fields installed in San Francisco since 2006, all but one of which belong to San Francisco Recreation and Parks Department (SFPRD). As shown in Figure 1, four are located within the Westside Groundwater Basin: South Sunset Playground, Beach Chalet Soccer Fields, Minnie Lovie Field, and University of San Francisco’s (USF) Benedetti Field.

Background
A representative of USF called SFPUC WRD in November 2018 for guidance on how to conduct a test that potentially could allow USF to percolate storm drainage1 from its synthetic turf field rather than direct it to the combined sewer system. Synthetic turf was installed with organic infill material at its Benedetti Field in 2016, located in the northeast corner of the Westside Groundwater Basin (Figure 1). SFPUC WRD and Wastewater Enterprise (WE) staff had informed USF in 2015 that water quality sampling would be required before field drainage could be allowed to percolate to groundwater. SFPUC and SFRPD had prepared draft synthetic turf drainage sampling plans in 2010 and 2011 and sampled storm drainage from two SFRPD synthetic turf fields during 2010-2012. As of November 2018, policies and guidelines for synthetic turf drainage remained draft, the collected field data were not fully analyzed, and there was a lack of consensus among SFPUC divisions and other City departments on this subject.

Objectives
To prepare a reply to USF and support the establishment of a consensus policy, this technical memorandum presents (a) a summary of past studies, discussions, and draft policies related to the use of synthetic turf in San Francisco; (b) an analysis of the field data collected in 2010- 2012; and (c) an updated literature review. These are presented in Appendices A, B, and C, respectively, and summarized below. Comments on this document will be solicited from SFPUC water resources and wastewater staff, SFRPD, and San Francisco Department of Public Health

1 As used here, storm drainage refers to the combination of rainfall runoff and infiltration (or leachate) captured by a synthetic turf field drainage collection system.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

2 (SFDPH), with the goal of reaching a consensus policy. Given the approaching wet season, USF will be advised of the existing guidance for sampling drainage from its synthetic turf field.

Existing Guidance for Evaluating Synthetic Turf Drainage Appendix A chronologically lists (Table A-1) and summarizes 24 documents and documented discussions from 2007 to 2018 related to stormwater drainage from synthetic turf Fields in San Francisco.

The most recent guidance for evaluating whether drainage from a synthetic turf athletic field may be allowed to percolate to groundwater is from the May 2011 First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan prepared by SFPUC and SFRPD. This plan and the 2010 draft plan it replaced guided SFPUC’s collection of stormwater drainage from synthetic turf installed at SFRPD’s South Sunset Playground and Garfield Square Park during 2010-2012.

The 2011 plan recognized the potential for greater degradation of synthetic turf materials after frequent field use during the dry summer, which could lead to higher contaminant loading during the first rain events of the season. For this reason, the plan called for collecting three samples, one hour apart, beginning as soon as possible after rainfall begins during the first substantial rain event (greater than 0.25 inches) of the season (i.e., seasonal “first flush”). The 2010 plan called for collecting one sample from a storm’s “first flush” (i.e., as soon as possible after a storm begins) without targeting a particular time of the season. As recommended by the 2008 San Francisco Playfields Task Force, percolation to groundwater would not be allowed unless the sampled drainage meets drinking water standards.

South Sunset Playground and Garfield Square Park Sample Results Appendix B provides a review of the 2010-2012 results from sampling synthetic turf drainage at South Sunset Playground and Garfield Square Park. A total of eight samples were collected on five different dates from each field under a wide range of conditions (mid-season and early season; wet and dry years; storm rainfall at the time of sample collection ranging from approximately 0.14 to 1.1 inches; samples collected from 3 to 31 hours after storm rainfall began; see Table B-1).

Samples collected from South Sunset Playground during two early-season rainfall events in 2011-2012 did not meet drinking water quality standards for dissolved iron and a semi-volatile organic compound (SVOC). These events occurred four or more years after the fields were installed. Excluding total metal concentrations,2 all of the Garfield Square Park samples met drinking water standards.

Three South Sunset Playground samples collected from early-season events in 2011-2012 had concentrations of the SVOC bis-(2-ethylhexyl)-phthalate that equaled or exceeded the 4 μg/L drinking water maximum contaminant level (MCL) for this compound. Bis-(2-ethylhexyl)-

2 The potential for metals to reach groundwater is indicated significantly more by dissolved metals than total metals.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

3 phthalate is a plasticizer used to soften rubber that may have been released from the SBR turf infill (styrene butadiene rubber, or crumb rubber, from recycled tires and tire shreds) or other components of the drainage system. This SVOC was detected in four of the other eight samples collected in 2010-2011 at concentrations below the MCL. For the early-season event when three samples were collected one hour apart, concentrations of this SVOC ranged from below detection to 57 μg/L. Dissolved iron concentrations exceeded the secondary drinking water MCL in the second two of the three hourly samples (possibly derived from steel belts and beads included in the tire source material). These detections became the basis for not allowing the infiltration of synthetic turf drainage at South Sunset Playground or the Beach Chalet soccer fields where SBR infill also was used.

These results suggest the following:
 The potential for contaminant concentrations in synthetic turf drainage to exceed drinking water standards may be greatest within fairly narrow windows of time during early- season rainfall events.
 Because drinking water standards were exceeded in samples collected four or more years after the synthetic turf was installed, these fields may provide an ongoing contaminant source as a result of degradation of the turf materials.

Stormwater Management Perspective
At a March 2015 meeting, SFPUC water resources and wastewater staff and management and the San Francisco City Attorney discussed the potentially conflicting goals of stormwater management and groundwater quality protection in the Westside Basin (see item 20, Table A-1).

Stormwater guidelines promote the use of green infrastructure and best management practices (BMPs) to infiltrate stormwater without testing for water quality. The City Attorney expressed that requiring synthetic turf drainage to meet drinking water standards before allowing it to percolate to groundwater was too stringent and set a poor precedent for implementing green infrastructure. Developers have pointed out inconsistencies between policies and believe that a requirement to meet drinking water standards is unreasonable. Other jurisdictions (e.g., Santa Clara Valley Water District) at that time generally lacked groundwater protection standards for synthetic turf fields.

The May 2016 San Francisco Stormwater Management Requirements and Design Guidelines (see item 22, Table A-1) cites groundwater recharge as one of the benefits of “treating stormwater as a resource rather than a waste product.” Stormwater controls for large projects must be designed to infiltrate, evapotranspire, bioretain, and/or biotreat stormwater generated by the 90th percentile, 24-hour storm (approximately 0.75 inches of rain with a rainfall intensity of approximately 0.24 inches per hour). Pre-treatment may be needed to allow stormwater to recharge groundwater, including biological processes to “filter pollutants.” “Full treatment” may be required where the infiltration rate exceeds 5 inches per hour. A 10-foot minimum vertical separation is required between the base of an infiltration BMP and the seasonal high groundwater level. The guidelines lack specificity on how to evaluate the potential for groundwater Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

4 contamination. Nor is it clear how all types of dissolved contaminants can be sufficiently “filtered” by biological processes and a 10-foot vertical separation from groundwater. The guidelines make no specific reference to synthetic turf.

In a July 2018 discussion by email (see item 23, Table A-1), SFPUC water resources staff confirmed that the requirements for sampling synthetic turf apply even where alternative materials are used, whereas wastewater staff said this requirement may be worth revisiting.

Wastewater staff said that they and SFRPD had determined that the maintenance and eventual replacement of synthetic turf (e.g., every 10 years) would not trigger the Stormwater Management Ordinance.

Other Reviewed Literature
Appendix C presents a chronological list of 23 references related to the environmental effects of synthetic turf and summarizes their findings relevant to potential groundwater impacts.

A 2009 study by the New York State Department of Environmental Conservation concluded that application of a dilution-attenuation factor could support the use of crumb rubber as a synthetic turf infill material without causing significant impacts to groundwater quality. As synthetic turf drainage moves through soil to the groundwater table, contaminant concentrations are attenuated by adsorption and degradation, and further reduced by dilution when mixed with groundwater.

Similarly, a 2010 study by the Connecticut Department of Environmental Protection did not identify significant risks to groundwater from synthetic turf fields.

A 2010 Stanford study (Cheng and others, 2014) concluded that relatively effective natural attenuation of contaminants from synthetic turf can be expected in surface water and groundwater. A 2014 journal publication by the same authors stated that dilution by infiltrating rainwater and groundwater is expected to reduce the toxicity of synthetic turf drainage and lower the associated ecological risk. Concentrations of heavy metals and organic contaminants in field drainage were generally below regulatory limits.

A 2015 study of scrap-tire leachate offered no confirmation that synthetic turf fields are safe and warned that acidic rainwater or groundwater could increase the rate of leaching (Selbes and others, 2015).

A 2018 risk assessment concluded that a growing body of literature suggests that recycled rubber infill in synthetic turf poses negligible risks to human health (Peterson and others, 2018).

Conclusions
This review supports the following conclusions and recommendations:
 Maintain the requirement that synthetic turf drainage must be sampled before allowing it to percolate to groundwater, as prescribed in the 2011 First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan. However, based on the 2010-2012 sampling results for two SFRPD synthetic turf fields, it should be recognized that the required sampling may not coincide with potentially narrow windows of time when Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

5 contaminant concentrations are greatest. Whether or not to require additional or ongoing sampling could be considered in future revisions to this policy.  Consider evaluating the fate of contaminants if synthetic turf drainage is allowed to migrate to and reach groundwater. As stated in the 2008 New York study, application of a dilution-attenuation factor could support allowing synthetic turf drainage to contribute to groundwater recharge without causing significant impacts to groundwater quality because of the processes of adsorption, degradation, and dilution.  Further discussions between SFPUC divisions and other City departments are needed to achieve consensus on these issues and resolve potential inconsistencies between stormwater management and groundwater protection policies.

Attachments
Table 1. San Francisco Athleti c Fields with Synthetic Turf Figure 1. San Francisco Athleti c Fields with Synthetic Turf Appendix A: Summary of Previous Plans, Policies, Discussions, and Evaluations Regarding Synthetic Turf Fields in San Francisco
Table A-1. Timeline of Documents Related to Stormwater Drainage from Synthetic Turf Athletic Fields in San Francisco
Appendix B: Review of 2010-2012 Sampling of Synthetic Turf Drainage at South Sunset Playground and Garfield Square Park
Table B-1. Rainfall Preceding S ynthetic Turf Infiltration Samples at South Sunset Playground and Garfield Square Park, 2010-2012
Table B-2. Monthly Rainfall, Dow ntown San Francisco NOAA Station, 1921-2019 Table B-3. Results of Synthetic Turf Infiltration Sampling, South Sunset Playground, 2010- 2012
Table B-4. Results of Synthetic Turf Infiltration Sampling, Garfield Square Park, 2010-2012 Table B-5. Summary of Water Qua lity Constituents with Elevated Concentrations Detected in Synthetic Turf Drainage at South Sunset Playground and Garfield Square Park Figure B-1. Monthly and Daily Rainfall Relative to Synthetic Tu rf Sample Dates, 2010-2012 Figure B-2. Hourly Rainfall During Storms When Synthetic Turf I nfiltration Sampled at South Sunset Playground
Figure B-3. Hourly Rainfall During Storms When Synthetic Turf I nfiltration Sampled at Garfield Square Park
Appendix C: Synthetic Turf Literature Review
Year
Installed
West-
side
Basin
Approx-
imate
Acreage
Percent
of Park
Land

1. Franklin Square Park 2003 1.9 0.05%

2. Silver Terrace Playground 2003 3.1 0.09%

3. Crocker Amazon Playground 2006-08 8.9 0.25%

4. Garfield Square Park* 2006-08 0.9 0.03%

5. South Sunset Playground* 2006-08  2.2 0.06%

6. Youngblood-Coleman Playground 2006-08 2.5 0.07%

7. Raymond Kimbell Playground 2010 3.0 0.09%

8. Mission Playground 2012 0.4 0.01%

9. Minnie Lovie Field 2014  5.3 0.15%

10. Beach Chalet Soccer Fields 2015  8.2 0.23%
All synthetic turf fields 36.4 1.0%
Natural turf athletic fields 177 5.1%
All other park land 3,303 94.4%
Total park land 3,500 100%
Other

11. USF Benedetti Field 2016  2.1
Synthetic Turf Athletic Fields
San Francisco Recreation & Parks Dept.
* Field runoff or leachate sampled February, March, and December 2010, February and October 2011, and January 2012.

Sources: SFRPD, 2008, 2009, https://sfrecpark.org/permits-and-reservations/athletic- fields/athletic-fields-directory/, and Google Earth.

Table 1
San Francisco Athletic Fields with Synthetic Turf
Tbl 1 Summary of SF Synth Turf Fields v5.xlsx 9/16/2019

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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A-1

Appendix A: Summary of Previous Plans, Policies, Discussions, and Evaluations Regarding Synthetic Turf Fields in San Francisco Table A-1 lists 24 documents and documented discussions chronologically from 2007 to 2018 regarding synthetic turf in San Francisco. The summaries of these materials that are provided below focus on aspects related to groundwater quality.
2007 Evaluation by for San Francisco Department of the Environment In December 2007, the Washington Toxics Coalition provided an evaluation of synthetic turf prepared for the San Francisco Department of the Environment (SFE) (Table A-1, items 1 and 2). The objective of this evaluation was to inform decision making regarding the purchasing of synthetic turf given the potential leaching of toxic substances from turf components. The evaluation found that prior studies on this topic had been inconsistent and/or inconclusive regarding environmental issues associated with synthetic turf.

The evaluation noted that infill material derived from recycled rubber tires contains several components of potential water quality concern, including zinc, polycyclic aromatic hydrocarbons, nonylphenol, bromine, and lead. Zinc toxicity is relatively low for humans but more significant to aquatic life. The presence of bromine may indicate that a material contains brominated flame retardants, or polybrominated diphenyl ethers (PBDEs). The study noted that natural turf treated with fertilizers and pesticides also cannot be considered risk free.

The evaluation screened 25 different elements in representative samples of synthetic turf, backing, infill, and shock pads using an x-ray fluorescence analyzer. The highest measured bromine content of infill and shock pad samples was 0.4 percent. The highest lead content was about 0.2 percent in some backing and shock pad samples. Most of the infill and some of the turf samples contained significant amounts of zinc, generally ranging from 4 to 10 percent of the material tested.

The study recommended requesting manufactures disclose the full list of synthetic turf ingredients and staying abreast of developments regarding the need and potential to recycle synthetic turf materials at the end of their useful life. 2008 Synthetic Playfields Task Force
A Synthetic Playfields Task Force convened by SFPRD presented its findings and recommendations in an August 2008 report (Table A-1, item 3). The task force reviewed and evaluated available scientific research on potential environmental and human health risks associated with synthetic turf playfields, including potential groundwater contamination from synthetic turf drainage.

The task force’s water quality study group reviewed 22 studies and papers regarding the occurrence, leaching, and fate of heavy metals (particularly lead and zinc) and other known carcinogens associated with synthetic turf. Its findings included instances of detected contaminants in synthetic turf drainage that impacted localized areas but declined in Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

A-2

concentration over time. SFE commented that concentrations in synthetic turf drainage were not expected to approach levels of concern in “normal” synthetic turf installations above the water table.

The recommendations of the task force included the following:
 Screen proposed synthetic turf materials by requiring that manufacturers list all ingredients and provide material safety data sheets (MSDS); perform leachate tests on synthetic turf samples to determine if the leachate meets drinking water quality standards; evaluate alternative products; and confer with other users of synthetic turf.  Conduct, or participate in, field tests to evaluate the water quality of synthetic turf drainage.
 Install synthetic turf fields above the water table and in areas that do not flood. Construct drainage systems that allow leachate to either infiltrate and percolate to groundwater or discharge to the combined stormwater and wastewater system. Consult with the San Francisco Public Utilities Commission (SFPUC) to weigh the relative benefits of water conservation, groundwater recharge, and water quality protection.  Allow infiltration to groundwater if the synthetic turf drainage meets drinking water standards; otherwise, collect the turf drainage and discharge it to the sewer system (after detaining on site as necessary to manage system capacity). 2009 San Francisco Synthetic Turf Standards
SFRPD developed synthetic turf standards in 2009 for the composition, post-consumer recycled content, and recyclability of synthetic turf products used in San Francisco (Table A-1, item 4).

The vendor must submit an analysis quantifying the content of their product. The maximum soluble concentrations allowed for chromium and lead are 0.05 and 0.0025 milligrams per liter (mg/L), respectively, whereas the maximum allowed concentration for soluble zinc is 250 mg/L in SBR (styrene butadiene rubber, or crumb rubber, from recycled tires and tire shreds) infill and

0.081 mg/L in non-SBR infill materials. Although the zinc standard for SBR infill is higher than the drinking water maximum contaminant level (MCL), the acidic solution used by the Waste Extraction Test is more aggressive at dissolving constituents from a material than water. 2010 Evaluation of Stormwater Management Alternatives for Beach Chalet Soccer Fields A February 2010 evaluation of alternative stormwater management systems was conducted for the planned installation of synthetic turf at the Beach Chalet soccer fields in Golden Gate Park within the Westside Groundwater Basin (Fall Creek Engineering, 2010; Table A-1, item 5).

At this location the water table is approximately 10 feet below ground surface and soils have a relatively high permeability on
the order of 1x10-3 centimeters per second. The expected drainage from these fields was assumed to contain fine sediment, possibly trace metals from the infill material, and bacteria.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

A-3

The recommended alternative was to construct unlined bioretention swales to manage and treat field drainage. This was the only alternative with the ability to treat and infiltrate the design

0.75-inch rainfall event without needing a retention facility or direct connection to the combined sewer system. This ecological approach would rely on plants, soil, and soil microbes to capture, treat, filter, transpire, infiltrate, and remove pollutants from stormwater as a result of chemical, biological, and physical processes. Its simple design and operation was expected to achieve a high level of treatment, an overall reduction in stormwater volume, and the attenuation of peak flows. The size could be reduced if the fields remained unlined and some drainage was allowed to infiltrate directly below the fields.
2010 Draft Synthetic Turf Stormwater Quality Monitoring and Sampling Plan SFPRD and SFPUC collaborated on a draft Synthetic Turf Stormwater Quality Monitoring and Sampling Plan to implement the recommendations of Synthetic Playfields Task Force and address public health and safety concerns that arose after SFPRD installed several synthetic turf playfields in San Francisco (Table A-1, item 6). A draft plan was released in February 2010.

The objectives of the plan were to collect stormwater quality data, determine potential impacts to groundwater, and assist with the planning and design of San Francisco playfields.

The synthetic turf fields at South Sunset Playground and Garfield Square Park were selected for sampling during the first and one subsequent storm event of the 2009-2010 and 2010-2011 rainy seasons. The San Francisco Groundwater Supply Project (SFGW) South Sunset well was constructed in 2007 adjacent to South Sunset Playground. Grab samples were to be collected as early as possible after the beginning of each storm to characterize the water quality characteristics of the storm’s “first flush.” The samples would be analyzed for physical parameters (pH, temperature, specific conductance, turbidity, total dissolved solids, and suspended solids); metals (total and dissolved); and volatile and semi-volatile organic compounds (VOC; SVOC). The draft plan specified lab, detection, and method limits; the collection of duplicate samples and trip blanks; and laboratory quality control procedures. 2010 February, March, and December Sampling Events at South Sunset Playground and Garfield Square Park
As part of assisting SFPRD with the design of the stormwater drainage system for the Beach Chalet synthetic turf playfields, SFPUC staff conducted stormwater quality monitoring in February, March, and December 2010 to evaluate the presence of contaminants in drainage from two existing synthetic turf playfields, South Sunset Playground and Garfield Square Park (the former is within the Westside Groundwater Basin) (Table A-1 item 7). The sampling objectives and protocol were consistent with the 2010 Draft Synthetic Turf Stormwater Quality Monitoring and Sampling Plan. As summarized below, the initial results were discussed in a meeting between SFPUC and SFPRD in April 2010.

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2010 Beach Chalet Field Renovation Project, Synthetic Turf Stormwater Discussion SFPUC staff prepared a May 2010 memorandum summarizing SFPRD's Beach Chalet synthetic turf project and the initial results from sampling stormwater drainage at two existing synthetic turf playfields. Additionally, SFPUC responded to action items from an April 2010 meeting with SFPRD at which the monitoring results were discussed (Table A-1, item 8).

The proposed 8.2 acres of synthetic turf playfields are approximately 300 feet or more from the South Windmill production well (constructed in 2000, this well was originally used for Golden Gate Park irrigation but is now being converted to potable use as part of the SFGW project). The depth to groundwater was 15 feet in October 2009 and could rise to less than 10 feet during the rainy season.

SFPUC directed SFRPD to design and implement an appropriate Best Management Practice (BMP) consistent with San Francisco’s Stormwater Design Guidelines if the project EIR determined that stormwater drainage from the playfields required collection and/or treatment before being allowed to infiltrate and percolate to groundwater. A stormwater BMP must be at least 150 feet from drinking water wells and comply with depth-to-groundwater limitations.

The February and March 2010 samples of synthetic turf drainage at two existing playfields were collected after more than 70 percent of average seasonal rainfall had occurred (see Table B-1), and thus were not representative of a seasonal first flush. No volatile or semi-volatile organic compounds were detected. Concentrations of total iron and manganese exceeded their respective California secondary MCLs in several of these samples, however concentrations of dissolved iron and manganese did not. The potential for metals to reach groundwater is indicated significantly more by dissolved metals than total metals. The sample results for pH, electrical conductivity, total dissolved solids, and dissolved zinc differed between the two fields, and total metal concentrations appear to have correlated positively with total suspended solids, suggesting that pretreatment to remove suspended solids may be needed. See Appendix B for a more detailed discussion of the sample results.

Coordination with the SFPUC Wastewater Enterprise would be needed to determine if pre- treatment is necessary. The EIR process should not be expected to provide technical standards protective of groundwater. If water quality concerns remained after completion of the sampling plan, SFPUC would ask for a drainage system design that either does not directly percolate to groundwater or discharges to the sewer system. To ensure the long-term protection of groundwater, SFPUC may recommend leachate tests of the proposed synthetic turf materials, a post-construction stormwater monitoring plan, and an operation and maintenance plan. SFPUC encouraged
SFPRD to continue evaluating alternative infill materials. 2011 First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan SFPRD and SFPUC completed a revised version of the synthetic turf sampling plan in May 2011, entitled First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan (Table A-1, item 9). This plan followed the 2009-10 and 2010-11 collection of mid-season samples of synthetic turf drainage from South Sunset Playground and Garfield Square Park. The Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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plan recognized the potential for greater degradation of the synthetic turf materials after frequent use of the fields during the long, dry summer, which could lead to higher contaminant loading during the first rain events of the season. For this reason, the revised plan called for collecting seasonal first-flush samples at these same locations during the first substantial rain event (>0.25 inches) of the 2011-12 wet season.

The plan called for collecting three samples, one hour apart, as soon as possible after the beginning of a rain event. The plan’s sampling and analysis procedures and methods were essentially the same as the 2010 draft plan. SFPUC was to interpret and report on the sample results in a brief memorandum.
2011-2012 Sampling Events at South Sunset Playground and Garfield Square Park SFPUC staff collected additional stormwater quality samples of synthetic turf drainage at South Sunset Playground and Garfield Square Park in February and October 2011 and January 2012 (see Table B-1). The sampling objectives and protocol were consistent with the 2011 revised Synthetic Turf Stormwater Quality Monitoring and Sampling Plan. Cumulative seasonal rainfall when these samples were collected ranged from 2 to 68 percent of San Francisco’s approximate 21 inches of average annual rainfall. As discussed in greater detail in Appendix B, two South Sunset Playground samples collected after completion of the draft EIR exceeded the MCL for the SVOC bis-(2-ethylhexyl)-phthalate (a plasticizer used to soften rubber). Concentrations of total iron and total manganese (possibly derived from steel belts and beads included in the tire source material) exceeded secondary MCLs in several of the South Sunset Playground samples, and dissolved iron exceeded the secondary MCL in two of these samples. The concentration of total iron exceeded the secondary MCL in one sample from Garfield Square Park. The potential for transport to groundwater is most indicated by dissolved rather than total metal concentrations.

Per the 2011 Beach Chalet Athletic Fields EIR, a majority of the samples from both fields exceeded dissolved copper environmental screening levels for marine surface water and groundwater.
3 2011 Beach Chalet Athletic Fields Renovation Draft Environmental Impact Report (EIR) As described in the October 2011 EIR for the Beach Chalet playing fields (Table A-1, item 10), the proposed synthetic turf consists of four components: fiber, infill, backing, and underlayment.

As designed, the fiber (synthetic grass) consists of polyethylene, the infill consists of approximately 70 percent SBR and 30 percent sand, the backing consists of permeable woven and un-woven polypropylene fabrics that provide strength and vertical drainage, and the underlayment consists of drainage tile or an aggregate rock base. The composition of SBR infill material can vary widely due to the variable composition of the tire source material. At the end

3 Environmental screening levels established by the San Francisco Regional Water Quality Control Board. Per the EIR, exceedances do not necessarily indicate that adverse effects could occur given the conservative assumptions used in developing the screening levels. The 3.1 μg/L screening level for copper in groundwater assumes potential discharge to aquatic habitat. The California Regulatory Action Level for copper in drinking water is 1,300 μg/L.

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of its anticipated 10 or more year lifespan, the turf would be returned to a turf manufacturer for reuse/recycling and replaced with new synthetic turf.

A literature review conducted for the EIR summarized the following prior studies in addition to some of the studies summarized above:
 A 2007 study by the California Integrated Waste Management Board concluded that leachate from tire shreds used in outdoor applications, such as playground surfaces, was unlikely to cause adverse effects, particularly where playfields are installed above the water table.
 A 2007 study conducted in France found that concentrations of metals and organic chemicals detected in synthetic turf leachate samples were generally lower than the applicable drinking water standards. The samples exhibited slight acute and chronic toxicity 15 days after installation, but none of the samples showed toxicity three months after installation.
 A 2009 report on studies conducted by New York State found that synthetic turf has the potential to leach zinc, aniline, phenol, and benzothiazole, although the laboratory procedures used were more aggressive than would occur due to rainfall. One sample of stormwater drainage from synthetic turf contained zinc, chromium, copper, lead, and nickel at concentrations below New York surface water standards. Semi-volatile organic compounds were not detected in groundwater samples collected down gradient of four synthetic turf installations.
 Connecticut State agencies conducted laboratory studies in 2010 that found a potential for synthetic turf to leach metals, especially copper and zinc. Stormwater samples collected from four fields contained benzothiazole (associated with dyes and rubber), barium, copper, iron, vanadium, and zinc. Concentrations of aluminum, barium, and zinc exceeded aquatic toxicity criteria in at least one sample. Zinc was identified as a potential risk to surface waters.

The EIR concluded that the project’s potential to impact groundwater quality was less than significant given that the synthetic turf drainage would be collected by an underdrain and discharged to the combined sewer system until sampling by SFRPD indicated that the water quality was suitable for infiltration. SFPUC was expected to provide guidance on the required number of sampling events and the sampling parameters. The EIR recommended that future studies evaluate the concentration of metals in runoff from grass fields to help assess the contribution of metals due to synthetic turf.

As described above, the SVOC bis-(2-ethylhexyl)-phthalate was detected above its MCL in two samples of synthetic turf drainage at South Sunset Playground after completion of the draft EIR.

As a result, the infiltration of synthetic turf drainage has not been allowed at either South Sunset Playground or the Beach Chalet athletic fields following construction.

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2013 Draft Synthetic Turf Requirements for the Large Landscape Grant Program The SFPUC Water Resources and Wastewater divisions prepared an internal memorandum in July 2013 discussing draft synthetic turf requirements for the Large Landscape Grant Program (LLGP) (Table A-1, item 11). The memorandum states that (a) synthetic turf provides substantial water savings by reducing the amount of potable water used for irrigation and (b) installations outside of the Westside Groundwater Basin would not be subject to additional requirements.

For projects within the Westside Basin, additional measures to protect groundwater quality would be required to apply for LLGP grant funding. Such requirements “may vary depending on the project size, location, and scope.” The memorandum’s recommended requirements remained uncertain and incomplete given that its bullet lists of requirements ended with several blank, queried lines (i.e., “ ??”).

Generally, however, dual-liner systems are needed for synthetic turf installations in the Westside Basin to allow drainage to either percolate to groundwater or discharge to the combined sewer system. Percolation to groundwater would be allowed only if the water quality of collected drainage samples met drinking water standards. In cases where percolation is not allowed, synthetic turf drainage during peak rainfall events must be held in detention basins for at least 15 minutes prior to discharging to the combined sewer.

Prior to submitting an LLGP-grant application for synthetic turf, the memorandum states that LLGP applicants within the Westside Basin must provide SFPUC with the project location and size; a description of the proposed drainage system; the manufacturer and type of synthetic turf; and the type of infill (e.g., SBR, sand, cork) in order for SFPUC to make a preliminary determination regarding any additional requirements.
2013 Environmental Testing Protocols for Procuring Synthetic Turf Products A consultant for SFPUC reviewed and proposed environmental testing protocols for procuring synthetic turf products in an August 2013 report (D. Teeter Consulting, 2013; Table A-1, item 12). As proposed, potential suppliers of synthetic turf products would need to submit samples for testing (a) to ensure compliance with Proposition 65 and (b) to ensure that they do not leach contaminants at concentrations that could adversely impact groundwater. The report proposed calculating target leachate concentrations by multiplying water quality screening levels or goals by a dilution attenuation factor of 20.
2013-2014 SFSU Recreation Wellness Center
As proposed, the SFSU Recreation Wellness Center (RWC) included a synthetic turf recreation field. At a December 2013 meeting on the proposed project, SFPUC water resources and wastewater staff described the guidelines for installing and monitoring synthetic turf fields to prevent groundwater contamination (Table A-1, items 13 and 14). The granulated rubber and the ethylen
e propylene diene monomer (EPDM) rubber mat can leach zinc, lead, and other pollutants. Rainfall and stormwater runoff penetrating through the synthetic turf must meet Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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drinking water standards before being allowed to recharge the Westside Groundwater Basin aquifer. The typical approach is to construct the field with a liner, initially divert all the turf drainage to the combined sewer system and collect and test samples to determine if the drainage meets drinking water standards. If the drainage meets these standards, it may be allowed to infiltrate and percolate to groundwater; if it does not, the water must be directed to the sewer system. Some synthetic turf materials are less likely to leach heavy metals, such as those made of natural materials (e.g., coconut fiber, cork). However, none of the materials are known to be free of potential contaminants.

SFPUC Water Enterprise’s guidelines for synthetic turf were summarized in a follow-up January 2014 email (Table A-1, item 15):

Synthetic turf fields located within the boundary of the Westside Groundwater Basin in San Francisco should be designed and monitored to protect groundwater quality. Water, including rainfall and stormwater runoff, penetrating through the synthetic turf system must meet drinking water standards before being allowed to percolate downward to recharge the aquifer in the Westside Basin.

Notes from a subsequent meeting in January 2014 (Table A-1, items 16 and 17) provided the following list of synthetic turf materials with possibly lower leaching potential: virgin EPDM rubber; other virgin polymers; thermoplastics (TPE); polymer-coated quartz sand; ceramic- coated beads; and organic infill made from a blend of shredded coconut husk and cork. The long-term durability and performance of these materials is uncertain, however. 2014 SFPUC Position on Synthetic Turf
In March 2014 SFPUC provided the following response to a public inquiry about its position on synthetic turf (Table A-1, item 18): synthetic turf fields within the boundary of the Westside Groundwater Basin in San Francisco should be designed and monitored to protect groundwater quality. Water, including rainfall and stormwater runoff, that infiltrates the synthetic turf system must meet drinking water standards before being allowed to percolate and recharge the aquifer. 2015-2018 USF Benedetti Baseball Field
A USF representative conferred with SFPUC water resources and wastewater staff in February 2015 regarding the proposed design for reconstructing USF Benedetti Baseball Field with synthetic turf (Table A-1, item 19). As proposed, the design included a fully lined field with a drainage detention system that discharged to the combined sewer system. Instead of SBR, the design used an organic infill material with available information on its chemical composition.

USF wished to allow the drainage to percolate to groundwater after conducting any required testing. SFPUC staff said they would review the sampling plan and analytical results for field drainage under as-built conditions in order to determine whether to allow infiltration, regardless of whether
the infill material was organic or SBR.

After constructing the field with coconut husk and sand infill material in 2016, a USF representative contacted SFPUC in November 2018 to ask about required testing prior to Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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allowing the synthetic turf drainage to infiltrate into dry wells constructed under the field (Table A-1, item 24). USF’s approved Final Stormwater Control Plan stated that SFPUC would permit infiltration after post-construction monitoring demonstrated that the field drainage met drinking water standards. The USF representative asked: if those requirements were still applicable; whether the City had pre-approved any synthetic turf materials; what sampling procedures and frequency were needed; and whether full Title 22 analyses were needed. 2015 Synthetic Turf Policy Discussion Meeting Minutes
Staff and management for the SFPUC water resources and wastewater enterprises, along with the San Francisco City Attorney, met March 4, 2015 to discuss the potentially conflicting goals of stormwater management and groundwater quality protection in the Westside Basin (Table A-1, item 20). Stormwater design guidelines promote the use of green infrastructure and BMPs to infiltrate stormwater without testing for water quality. Whereas, draft policies to protect Westside Basin groundwater quality require synthetic turf drainage to meet drinking water standards before allowing it to percolate to groundwater, consistent with the 2008 Synthetic Playfields Task Force report.

The City Attorney expressed that requiring synthetic turf drainage to meet drinking water standards before allowing it to percolate to groundwater was too stringent and set a poor precedent for the implementation of green infrastructure. Also, developers have pointed out the conflicts between these policies and believe that requirements to meet drinking water standards are unreasonable. It was noted that other jurisdictions (e.g., Santa Clara Valley Water District) have widely varying standards regarding setbacks between stormwater infiltration infrastructure and drinking water wells, and generally lacked groundwater protection standards for synthetic turf fields.
2016 Public Works Code, Stormwater Management Requirements, Ordinance 64-16 San Francisco adopted its first Stormwater Management Ordinance in 2010, requiring the installation and maintenance of stormwater management controls for development and redevelopment projects meeting specific area and project type criteria (Table A-1, item 21). A revised Stormwater Management Ordinance was approved in April 2016. The revised ordinance specifies Stormwater Management Requirements intended to reduce the volume of stormwater entering the City's combined and separate sewer systems, and to protect and enhance the quality of receiving waters.

As stated in the ordinance, pollutants of concern that potentially occur in urban runoff include sediments, non-sediment solids, nutrients, pathogens, bacteria, oxygen-demanding substances, petroleum hydrocarbons, heavy metals, floatables, polycyclic aromatic hydrocarbons (PAHs), trash, pesticides, and herbicides. Potential sources of these pollutants include vehicle emissions, wastes from vehicle maintenance, pesticides, household hazardous wastes, pet wastes, and trash.

Potential impacts from these pollutants include increased turbidity, nutrient enrichment, bacterial contamination, toxic compounds, temperature increases, and increased trash and debris.

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The ordinance calls for Post-Construction Stormwater Controls designed to (a) reduce pollution in stormwater runoff and/or (b) reduce the rate or volume of runoff through infiltration, retention, non-potable reuse, detention, direct plant uptake, and filtration. These controls are intended to enhance the function and capacity of the City's separate and combined sewer systems by reducing stormwater runoff rates or volumes; controlling the discharge of contaminants from spills, dumping, or disposal into the City's sewer and drainage systems; and providing pretreatment. These controls must be safe and properly maintained.

Per the ordinance, "natural vegetated soil can both absorb rainwater and remove pollutants, providing a very effective purification process." The ordinance calls for Post-Construction Stormwater Controls using green infrastructure that mimics pre-development drainage patterns and hydrologic processes by increasing retention, detention, infiltration, and treatment of stormwater at its source.
2016 San Francisco Stormwater Management Requirements and Design Guidelines The May 2016 San Francisco Stormwater Management Requirements and Design Guidelines were prepared by SFPUC and others to facilitate compliance with the 2016 revised Stormwater Management Ordinance (Table A-1, item 22). Increased groundwater recharge as a result of these requirements is cited as one of the benefits of “treating stormwater as a resource rather than a waste product.” The following paragraphs are paraphrased from this document.

Green infrastructure is aimed at removing pollutants and treating the first flush, defined in this case as the runoff generated during the beginning of a rain event that mobilizes most of the pollutants and debris accumulated since the last rain.

Stormwater controls for large projects under SFPUC jurisdiction must be designed to infiltrate, evapotranspire, bioretain, and/or biotreat the stormwater volume generated by the 90th percentile, 24-hour storm (approximately 0.75 inches of rain with a rainfall intensity of approximately 0.24 inches per hour).

Because these systems facilitate infiltration, the potential for groundwater contamination must be carefully evaluated, especially if the receiving groundwater is used as a potable water supply.

Stormwater treatment needed to allow groundwater recharge includes pre-treatment to remove solids and oils, and biological processes to “filter pollutants.” Subsurface infiltration systems, infiltration trenches, and infiltration basins may effectively remove sediments, nutrients, organic matter, and trace metals. However, where the infiltration rate exceeds 5 inches per hour (e.g., in the case of coarse sands) the runoff must be “fully treated” prior to infiltration, or by installing an 18-inch ASTM C33 sand layer at the base of the infiltration BMP.

To protect groundwater quality, a 10-foot minimum vertical separation is required between the base of an infiltration BMP and the seasonal high groundwater level (a 4-foot separation may be allowed in some cases). Infiltration systems are unsuitable for sites that use or store chemicals or hazardous materials, unless those materials can be effectively prevented from entering the system.

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Accidental spills or leaks that result in the unauthorized and unexpected discharge of waste materials into the stormwater conveyance system can pose a hazard to human health and the environment. Appropriate precautionary measures should be in place to prevent the accidental discharge of pollutants and to handle such events should they occur. This may include, but is not limited to, maintaining equipment and storage receptacles, training staff on the safe handling of waste materials, ensuring that potential pollutants are handled and stored in designated areas, and posting emergency contact information in the event of a spill.

The guidelines lack specificity on how to conduct an evaluation of potential groundwater contamination. Nor is it clear how dissolved contaminants of all types can be sufficiently “filtered” by biological processes and a 10-foot vertical separation from groundwater. The guidelines make no specific reference to synthetic turf. 2018 Discussion of Synthetic Turf Policies
SFPUC water resources and wastewater staff conducted a July 2018 discussion by email regarding policies for synthetic turf drainage (Table A-1, item 23). Wastewater staff acknowledged SFPUC’s requirement that drainage from large synthetic turf fields in the Westside Basin must be captured and tested before allowing infiltration. Water resources staff confirmed that these requirements apply even if alternative materials are used (e.g., organic, non- SBR infill materials). Wastewater staff commented this may be worth revisiting.

Wastewater staff clarified that (a) they do not regulate or comment on small artificial turf installations (e.g., at schools or playgrounds), (b) they do not allow synthetic turf as a component of stormwater BMPs, and (c) they have determined in coordination with SFPRD that the maintenance and eventual replacement of synthetic turf (e.g., every 10 years) does not trigger the Stormwater Management Ordinance.

Item Year Month Document Authors Document Type / Recipient Additional Recipients / Meeting Attendees

1. 2007 December Synthetic Turf Versus Natural Turf for Playing Fields

2. 2007 December Occurrence of Bromine, Lead, and Zinc in Synthetic Turf Components

3. 2008 August Synthetic Playfields Task Force Findings and Department Recommendations SFRPD Report (50 p. and attachments)
prepared for SFRPD Commission

4. 2009 July San Francisco Synthetic Turf Standards SFRPD

5. 2010 February Evaluation of Alternative Stormwater Management Systems, Beach Chalet, San Francisco
Fall Creek Engineering
(P. Hasse)
Letter report (9 p.) and attachments
prepared for Verde Design

6. 2010 February Draft Synthetic Turf Stormwater Quality Monitoring and Sampling Plan

SFRPD / SFPUC
(B. Eagon) Draft plan (3 p. and attachments)

7. 2010-12 various Results of Seven Synthetic Turf Infiltration Sampling Events at South Sunset Playground and Garfield Square Park SFRPD and SFPUC 2 tables

8. 2010 May Beach Chalet Field Renovation Project Synthetic Turf Stormwater Discussion
SFPUC
(B. Eagon, J. Gilman) Comments on draft plan (3 p.)

9. 2011 May First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan

SFRPD & SFPUC
(B. Eagon, S. Rhodes) Monitoring and sampling plan (7 p.)

10. 2011 October Beach Chalet Athletic Fields Renovation Draft Environmental Impact Report San Francisco Planning Department Draft EIR

11. 2013 July Draft Synthetic Turf Requirements for the Large Landscape Grant Program

WRD, WW, WC
(A. Dougherty, J. Gilman, K. Kortkamp)
Internal SFPUC memo to P.

Kehoe, J. Ortiz, M. Jurosek (2 p.)

12. 2013 August Environmental Testing Protocols for the Procurement of Synthetic Turf Products David Teeter Consulting, San Francisco Letter report (69 p.) prepared for SFRPD

13. 2013 December SFSU Recreation Wellness Center Coordination with CCSF SF State, URS (W. Bloom, A. Sansevero)
Agenda package (7 p.), meeting
notes (2 p.), sign-in sheet
SFMTA (C. Rivasplata, J. Robbins), SFDPW (N.

Elsner), SF Planning (A. Contreras, A. Smith), SFPUC
(K. Eickman, J. Gilman; K. Kortkamp, F. Lau, B. Pearl), Sandis (M. Kuykendall), Nelson Nygaard (J. Alba, F.

Napolitan), URS (A. Sansevero), SF State (W. Bloom)

14. 2014 January SFPUC follow up to SFSU Recreation Wellness Center Project Meeting December 3, 2013
SF Bureau of Environmental Management
(I. Torrey) Letter to SFSU (W. Bloom) (2 p.)

15. 2014 January SFSU Recreation & Wellness - Follow Up Meeting on Synthetic Turf Field

SFPUC, SFSU
(W. Bloom, J. Gilman) Email string URS (A. Sansevero), Sandis (M. Kuykendall, A.

Fortun), wrns studio (E. Kim), SFPUC (P. Kehoe)

16. 2014 January Design Options Related To Artificial Turf SF State Recreation Wellness Center Project SFPUC Meeting, January 8, 2014
URS
(A. Sansevero) Meeting agenda (2 p.)

17. 2014 January SFSU Recreation Wellness Center Sanitary Sewer Load Projections
SFPUC, SFSU (W. Bloom, J. Gilman, K.

Kortkamp, K. Eickman) Email string URS (A. Sansevero), Sandis (A. Fortun, M.

Kuykendall), SFDPW (C. Wong)

18. 2014 Feb-March Does SFPUC have a position on artificial turf? SFPUC (J. Ortiz, A. Frink), question from public (N. Buffum) Email string SFPUC (J. Gilman, A. Dougherty, P. Kehoe)

19. 2015 February USF Benedetti Baseball Field SFPUC (J. Gilm an, K. Kortkamp),
Hornberger+Worstell (J. Davis) Email string
USF (M. London, E. Miles), ARUP (R. Roderick-Jones,
J. Mong), Sports Plan Studio (J. Leider), HWI
Architects (B. Miller), SFPUC (K. Kortkamp, P. Kehoe)

20. 2015 March Artificial Turf Policy Discussion Meeting Minutes SFPUC WWE & WE (Z. Krystal) Meeting minutes (2 p.) T. Moala, S. Richie, J. Roddy, L. Regler, J. Gilman, K.

Kortkamp

21. 2016 April Stormwater Management Ordinance Deputy City Attorney (J. Roddy)
Public Works Code Ordinance 64-
14 22. 2016 May SF Stormwater Management Requirements and Design Guidelines
SFPUC, Parsons, Port of SF, Louts Water,
Water Resources Engineering (132 p.) S. Ramirez, P. Kehoe, S. Minick, S. Bloom

23. 2018 July Discussion of Artificial turf policies WW, WC, & WRD (K. Kortkamp, Ken, J. Scarpulla, J. Ortiz) Email string S. Ramirez, P. Kehoe, S. Minick, S. Bloom

24. 2018 November USF Benedetti Baseball Field -- Groundwater Infiltration of Artificial Turf Runoff
Hanson Bridgett LLP (A. Bishop),
SFPUC (N. Johnson) Email string
White papers prepared for San
Francisco Department of the
Environment (SFE)
Washington Toxics Coalition (P. Dickey)
Tbl A-1 Syn Turf document timeline.xlsx 9/19/2019
Table A-1
Timeline of Documents Related to Stormwater Drainage from Synthetic Turf Athletic Fields in San Francisco Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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Appendix B: Review of 2010-2012 Sampling of Synthetic Turf Drainage at South Sunset Playground and Garfield Square Park
Synthetic turf fields constructed with SBR (styrene butadiene rubber) infill were installed at South Sunset Playground (2.2 acres) and Garfield Square Park (0.9 acre) in San Francisco during 2006-2008 (Table 1). South Sunset Playground is within the Westside Groundwater Basin and Garfield Square Park is in the Mission District (see Figure 1 in main body of technical memorandum).

Following the recommendations of the August 2008 Synthetic Playfields Task Force4 convened by the San Francisco Recreation and Parks Department (SFRPD), storm drainage from these two fields was sampled during seven 2010-2012 storm events to evaluate whether the drainage met drinking water standards and could be allowed to percolate to groundwater. These samples were collected 2 to 4 years after the two synthetic turf fields were installed.

The sampling protocol for the first five storm events followed the February 2010 draft Synthetic Turf Stormwater Quality Monitoring and Sampling Plan3, which called for collecting grab samples as early as possible after the beginning of each storm in order to characterize the water quality of the storm’s “first flush.”
The final two storm events followed the May 2011 First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan3, which recognized the potential for greater contaminant loading during the first rain event of the season. The 2011 plan called for collecting seasonal first-flush samples at these same two fields during the first substantial rain events (greater than

0.25 inches) of the 2011-12 wet season. The plan specified collecting three samples, one hour apart, as soon as possible after the beginning of a rain event.

Sampled Storm Events
Staff from the Water Resources Division (WRD) of the San Francisco Public Utilities Commission (SFPUC) collected drainage samples from South Sunset Playground and Garfield Square Park during seven 2010-2012 storm events, as summarized in the following table:

Field Drainage Sample Dates
Storm event: 1 2 3 4 5 6 7
Synthetic Turf
Athletic Field
Feb
22-23,
2010
Mar 2,
2010
Dec 8,
2010
Dec
21-22.
2010
Feb
16-17,
2011
Oct
4-5,
2011
Jan
19-20,
2012
South Sunset Playground      
Garfield Square Park      
A total of eight samples were collected on five different dates from each field. Single samples were collected during the first six events and three samples were collected one hour apart at each

4 Summarized in Appendix A.

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field during the final sampling event in January 2012 (Table B-1). Because this field work was conducted by a single team, samples were collected from the two synthetic turf fields at different times and after different amounts of storm rainfall for events when both fields were sampled.

Table B-1 provides the following information for each sampled storm event:
 The time of day the sample was collected (not available for the February 2010 and October 2011 events).
 Seasonal rainfall through the day prior to sample collection, expressed as a percent of average water-year rainfall (i.e., October-September).
 Storm rainfall (inches) up to the time of sample collection.  A summary of water quality constituents detected at concentrations approaching or exceeding applicable standards.

The daily and hourly rainfall data used in this analysis are from the NOAA San Francisco Downtown station located in the Lower Haight near the corner of Hermann and Buchanan streets, about three-quarters of a mile east of the Westside Basin boundary (Figure 1). This station is approximately 4.5 miles from the South Sunset Playground and 1.6 miles from Garfield Square Park. Although rainfall data may be available for stations nearer to these fields, the NOAA Downtown San Francisco station was selected for its accessibility, reliability, hourly data, and nearly complete record. Table B-2 provides the 1921-2019 monthly rainfall record for the Downtown San Francisco station. Average water-year rainfall for the entire record is approximately 21 inches.5
Samples were collected under a wide range of conditions. Based on the NOAA Downtown San Francisco gauge:
 Total rainfall was approximately 112, 125, and 67 percent of average during the 2009-10, 2010-11, and 2011-12 water years, respectively (Figure B-1).  Storm-event rainfall at the time the samples were collected ranged from 0.14 to 1.07 inches (Table B-1). At least two samples from South Sunset Playground were collected after less than 0.25 inches of storm rainfall.
 Sample times ranged from 3 to 31 hours after the beginning of each storm event.  The February and March 2010 and February 2011 sampling events were conducted after 68 to 78 percent of average water-year rainfall had occurred (Table B-1, Figure B-1).

These events were not representative of a seasonal first flush.  Samples collected during two storms in December 2010 followed days of equal or greater rainfall and after 26 to 44 percent of average water-year rainfall had occurred.

5 This record appears to combine the historical records of other nearby stations, including the NOAA Mission Dolores station.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

B-3

 Samples were collected in October 2011 and January 2012 after only 2 and 17 percent of average annual rainfall, respectively (Table B-1). Although collected months apart during the same wet season, both samples may be considered representative of a seasonal first flush given generally low-rainfall conditions during the 2011-12 water year.

Figures B-2 and B-3 provide plots of hourly and cumulative storm rainfall in relation to the time each sample was collected at South Sunset Playground and Garfield Square Park, respectively.

Sample Results
Tables B-3 and B-4 provide the analytical results for water quality samples collected from synthetic turf drainage at South Sunset Playground and Garfield Square Park, respectively. Both total and dissolved metal concentrations were analyzed. Potential transport to groundwater is indicated by dissolved concentrations more so than total concentrations.

At South Sunset Playground (Table B-3):
 Concentrations of total iron ranged from 110 to 3,624 μg/L. Elevated iron (and manganese) may be derived from steel belts and beads included in the tire source material for the SBR infill
 Concentrations of dissolved iron ranged from less than 7 to 849 μg/L, exceeding the secondary maximum contaminant level (MCL) of 300 μg/L in two samples collected during the last monitored event.
 Concentrations of total manganese ranged from 19 to 144 μg/L, whereas concentrations of dissolved manganese ranged from less than 1 to 26 μg/L, below the secondary MCL of 50 μg/L.
 The semi-volatile organic compound (SVOC) bis-(2-ethylhexyl)-phthalate was detected in six samples and exceeded the MCL (4 μg/L) in samples collected during the last two storm events, ranging up to 57 μg/L. Bis-(2-ethylhexyl)-phthalate is a plasticizer used to soften rubber that may have been released from the SBR infill.  Concentrations of dissolved copper exceeded marine surface water and groundwater environmental screening levels in samples from four of the events.6 At Garfield Square Park (Table B-4):
 Concentrations of total iron ranged from 14 to 1,742 μg/L, exceeding the secondary MCL in one sample. None of the dissolved iron concentrations exceeded the MCL.

6 Environmental screening levels established by the San Francisco Regional Water Quality Control Board.

Exceedances do not necessarily indicate that adverse effects could occur given the conservative assumptions used in developing the screening levels (San Francisco Planning Department, 2011). The 3.1 μg/L screening level for copper in groundwater assumes potential discharge to aquatic habitat. The California Regulatory Action Level for copper in drinking water is 1,300 μg/L.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

B-4

 Concentrations of dissolved copper exceeded marine and groundwater environmental screening levels in samples from six of the events, exceeding screening levels by four to seven times in samples from the early-season storms (events 6 and 7).

Interpretation
Table B-5 provides a summary of water quality constituents detected at elevated concentrations in samples of synthetic turf drainage at South Sunset Playground and Garfield Square Park.

For iron and manganese samples collected from both fields, total versus dissolved concentrations were fairly uncorrelated or possibly inversely correlated. The highest concentrations of total iron and manganese tended to occur in samples collected during mid-season storms (events 1 through 5), whereas the highest dissolved concentrations of iron and manganese occurred during early- season storms (i.e., seasonal first flush; events 6 and 7).

At the South Sunset Playground, the SVOC bis-(2-ethylhexyl)-phthalate was detected in six of the eight samples, and equaled or exceeded the MCL of 4 μg/L in three samples. The highest concentrations (7 to 14 times the MCL) occurred in field drainage from the early-season storms (events 6 and 7).

The sample results for the early-season storms (events 6 and 7) appear to demonstrate that concentrations of dissolved metals (at both fields) and bis-(2-ethylhexyl)-phthalate (at South Sunset Playground) peak during the seasonal first flush. These events occurred four or more years after the fields were installed, suggesting that (a) the fields provide a continual source of these constituents or (b) the source is generated over time through degradation of the turf materials.

During the seventh storm event, concentrations of bis-(2-ethylhexyl)-phthalate in the drainage from South Sunset Playground declined from 57 μg/L to 4 μg/L to below detection in three samples collected one hour apart about 30 hours after the storm began. This observation, combined with detections of approximately 1 μg/L or less during the first four sampled events, suggest that elevated concentrations of bis-(2-ethylhexyl)-phthalate in the drainage from this field occur within a narrow window of time under particular storm conditions. Nevertheless, these detections became the basis for not allowing the infiltration of synthetic turf drainage at South Sunset Playground or the Beach Chalet soccer fields where SBR infill also was used.

% Avg.

Water-
Year
Rainfall
thru
Prior
Day*
Storm
Duration
Up to
Time of
Sample
(hrs)
Storm
Rainfall
Up to
Time of
Sample
(inches)
Detec-
tions
% Avg.

Water-
Year
Rainfall
thru
Prior
Day*
Storm
Duration
Up to
Time of
Sample
(hrs)
Storm
Rainfall
Up to
Time of
Sample
(inches)
Detec-
tions
2/23-24/2010 NR 71% - - a,c,f 2/23-24/2010 NR 75% - - f 3/2/10 6:30 78% 3 0.18 a,c,d 3/2/10 8:20 78% 4 0.32 a,f 12/8/10 10:05 26% 4 0.14 a,d,f -- - - - -
- - - - - - 12/22/10 8:15 44% 12 0.58 f
2/17/11 11:05 68% 15 0.73 a,c,d 2/17/11 11:40 68% 16 1.03 f 10/5/11 NR 2% - - e,f 10/5/11 NR 2% - - f
18:45 29 0.85 a,e,f 6:35 17 0.32 f
19:45 30 0.94 a,b,d,f 7:30 18 0.34 f
20:45 31 1.07 a,b,f 8:40 19 0.38 f
NR Not recorded, unable to estimate event rainfall prior to sample. Samples collected and analyzed by SFPUC. * Water year (Oct-Sep) average approximately 21 inches.

Detections summarized from Tables B-3 and B-4:
a Total iron above secondary MCL. e Bis-(2-ethylhexyl)-phthalate above MCL. b Dissolved iron above secondary MCL. f
c Total manganese above secondary MCL.
d Bis-(2-ethylhexyl)-phthalate below MCL.

Dissolved copper above environmental
screening levels for marine surface
water and groundwater.

Storm
Event
1/20/12
Sample Date
& Time
17%17%1/20/12
Sample Date
& Time
South Sunset Playground Garfield Square Park
6 5
3 2
4 1
7 Rainfall data for San Francisco Downtown,
NOAA Station USW00023272.

Table B-1
Rainfall Associated with Synthetic Turf Drainage Sampling Events at South Sunset Playground and Garfield Square Park, 2010-2012 NOAA Station San Francisco Downtown, California Lat Long Elev.

USW00023272 https://www.ncdc.noaa.gov/cdo-web/datasets/GHCND/stations/GHCND:USW00023272/detail 37.77 -122.4 45.7 Water Year Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep WY No. Yrs 1921 - - - 6.30 1.38 2.28 0.54 0.52 0.00 0.00 0.00 0.35 - - 1922 0.52 1.43 6.39 2.41 5.15 3.41 0.47 0.55 0.26 0.00 0.00 0.00 20.59 96% 1923 2.95 3.77 7.77 2.84 0.77 0.03 3.92 0.06 0.06 0.00 0.01 0.44 22.62 106% 1924 0.50 0.49 1.91 2.75 3.30 1.96 0.30 0.00 0.00 0.00 0.01 0.00 11.22 53% 1925 2.98 1.50 7.37 1.62 7.90 2.63 2.73 4.02 0.05 0.06 0.00 0.45 31.31 147% 1926 0.31 2.32 1.01 5.48 5.40 0.25 5.26 0.15 0.00 0.00 0.04 0.00 20.22 95% 1927 1.90 7.21 1.04 3.77 6.85 2.19 1.95 0.10 0.38 0.00 0.00 0.00 25.39 119% 1928 1.93 3.18 3.94 1.43 1.97 4.65 1.31 0.26 0.00 0.00 0.00 0.03 18.70 88% 1929 0.13 3.35 4.89 1.32 2.14 1.56 1.01 0.01 0.86 0.00 0.00 0.00 15.27 71% 1930 0.01 0.00 3.09 4.99 2.94 3.53 1.56 0.16 0.00 0.00 0.00 0.10 16.38 77% 1931 0.89 1.56 0.98 5.47 1.10 1.68 0.31 1.10 0.32 0.00 0.00 0.00 13.41 63% 1932 0.68 2.93 9.24 3.23 3.00 0.86 0.47 0.65 0.03 0.16 0.00 0.00 21.25 99% 1933 0.01 1.00 2.75 5.68 1.13 2.93 0.06 1.36 0.01 0.00 0.00 0.14 15.07 71% 1934 1.49 0.00 4.19 1.03 4.68 0.07 0.51 0.12 0.68 0.01 0.00 0.13 12.91 60% 1935 0.88 3.76 4.06 6.23 2.38 2.31 3.45 0.01 0.00 0.00 0.25 0.08 23.41 110% 1936 1.44 1.24 3.25 5.77 10.06 1.01 1.09 0.49 0.28 0.03 0.02 0.00 24.68 116% 1937 0.69 0.01 2.94 5.26 4.88 7.05 2.14 0.06 0.60 0.00 0.00 0.00 23.63 111% 1938 0.90 2.46 3.73 2.65 8.49 5.73 1.52 0.00 0.00 0.01 0.00 0.15 25.64 120% 1939 1.33 0.88 1.48 3.07 1.94 2.62 0.42 0.63 0.00 0.00 0.00 1.06 13.43 63% 1940 0.17 0.20 0.94 10.03 7.81 5.32 0.94 0.63 0.01 0.00 0.00 0.59 26.64 125% 1941 1.05 2.22 6.25 8.24 6.71 4.75 4.05 1.18 0.01 0.01 0.03 0.00 34.50 161% 1942 0.93 1.99 7.29 4.76 4.27 2.62 3.79 1.11 0.00 0.01 0.00 0.18 26.95 126% 1943 0.95 4.46 2.87 6.15 1.95 3.18 1.88 0.13 0.13 0.00 0.00 0.02 21.72 102% 1944 0.74 0.80 2.69 4.31 5.34 0.83 2.07 0.94 0.12 0.01 0.02 0.00 17.87 84% 1945 1.70 6.24 3.97 1.33 3.43 4.15 0.32 0.64 0.01 0.00 0.00 0.04 21.83 102% 1946 1.95 3.24 9.84 1.76 2.03 2.34 0.05 0.37 0.02 0.06 0.00 0.06 21.72 102% 1947 0.15 2.73 2.77 1.35 2.65 3.64 0.17 0.67 0.64 0.00 0.00 0.00 14.77 69% 1948 2.09 1.39 1.84 1.00 2.32 3.08 3.04 0.54 0.01 0.02 0.02 0.09 15.44 72% 1949 0.20 1.18 4.76 2.20 3.04 5.85 0.00 0.93 0.00 0.06 0.04 0.00 18.26 85% 1950 0.08 1.18 2.77 7.40 2.33 1.65 0.87 0.37 0.03 0.00 0.00 0.00 16.68 78% 1951 2.72 4.96 6.01 4.41 3.00 1.32 0.89 0.65 0.04 0.01 0.43 0.08 24.52 115% 1952 0.81 3.33 7.92 10.69 2.62 4.90 1.08 0.30 0.39 0.00 0.01 0.00 32.05 150% 1953 0.07 2.42 9.06 3.26 0.04 1.83 3.42 0.38 0.61 0.00 0.07 0.00 21.16 99% 1954 0.34 1.88 0.82 3.11 2.42 4.56 0.82 0.11 0.14 0.03 0.20 0.00 14.43 68% 1955 0.24 2.55 5.67 4.05 1.18 0.29 1.49 0.04 0.00 0.02 0.00 0.02 15.55 73% 1956 0.03 2.38 11.47 8.72 2.03 0.12 1.68 0.68 0.02 0.00 0.01 0.33 27.47 129% 1957 1.14 0.04 0.37 2.84 3.58 2.39 1.09 3.19 0.06 0.01 0.00 1.46 16.17 76% 1958 3.46 1.13 3.60 4.38 7.78 8.22 5.47 0.88 0.09 0.05 0.00 0.04 35.10 164% 1959 0.12 0.09 1.48 3.96 4.04 0.30 0.36 0.02 0.00 0.00 0.02 2.06 12.45 58% 1960 0.00 0.00 1.71 4.04 3.57 2.06 1.16 0.85 0.00 0.00 0.00 0.00 13.39 63% 1961 0.48 3.35 2.31 2.79 0.96 2.27 0.79 0.88 0.04 0.00 0.02 0.22 14.11 66% 1962 0.09 4.44 2.13 1.08 6.58 2.76 0.36 0.00 0.00 0.00 0.07 0.22 17.73 83% 1963 5.51 0.60 2.81 3.35 1.92 3.87 3.35 0.45 0.00 0.00 0.00 0.06 21.92 103% 1964 1.39 3.52 0.87 3.37 0.19 2.12 0.01 0.22 0.57 0.00 0.01 0.00 12.27 57% 1965 1.90 3.99 5.35 3.97 0.94 2.92 3.21 0.00 0.00 0.02 0.49 0.00 22.79 107% 1966 0.01 4.79 3.51 3.27 2.72 0.80 0.36 0.19 0.17 0.06 0.10 0.10 16.08 75% 1967 0.01 4.80 3.87 9.49 0.22 4.35 4.90 0.09 1.42 0.00 0.00 0.04 29.19 137% 1968 0.53 1.10 2.12 4.54 2.28 3.15 0.48 0.22 0.00 0.00 0.03 0.06 14.51 68% 1969 0.62 2.67 3.91 7.74 7.26 1.01 1.74 0.00 0.05 0.00 0.00 0.01 25.01 117% 1970 2.61 0.45 6.15 7.81 1.56 1.55 0.06 0.03 0.57 0.00 0.00 0.00 20.79 97% 1971 0.84 6.44 5.39 2.04 0.26 2.91 0.72 0.19 0.00 0.01 0.01 0.22 19.03 89% 1972 0.11 1.92 3.93 1.32 2.13 0.23 1.07 0.00 0.11 0.01 0.04 0.54 11.41 53% 1388%
% of All-Yr Avg
110% 12
76% 4
121% 3
102% 5
84% 14

SF precip stations monthly records v2.xlsx Tbl 9/9/2019 Table B-2
Monthly Rainfall, Downtown San Francisco NOAA Station, 1921-2019 NOAA Station San Francisco Downtown, California Lat Long Elev.

USW00023272 https://www.ncdc.noaa.gov/cdo-web/datasets/GHCND/stations/GHCND:USW00023272/detail 37.77 -122.4 45.7 Water Year Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep WY No. Yrs% of All-Yr Avg 1973 5.41 6.40 3.53 9.38 6.32 2.63 0.02 0.08 0.00 0.00 0.00 0.33 34.10 160% 1974 1.81 8.64 4.21 3.66 1.54 5.47 2.20 0.00 0.10 0.73 0.00 0.00 28.36 133% 1975 0.91 0.40 1.83 2.85 4.30 5.97 1.30 0.01 0.03 0.21 0.02 0.00 17.83 83% 1976 1.94 0.28 0.58 0.33 1.96 1.04 0.75 0.01 0.02 0.00 0.80 0.45 8.16 38% 1977 0.43 1.18 2.53 1.85 0.93 2.31 0.05 0.55 0.00 0.00 0.00 0.96 10.79 50% 1978 0.16 2.22 3.33 6.94 4.14 5.90 4.21 0.00 0.00 0.00 0.00 0.19 27.09 127% 1979 0.00 1.67 0.16 7.45 5.07 1.95 0.85 0.12 0.00 0.07 0.00 0.02 17.36 81% 1980 1.94 3.69 4.12 4.63 6.44 1.73 1.29 0.27 0.02 0.05 0.00 0.00 24.18 113% 1981 0.06 0.29 2.09 4.97 2.09 4.73 0.19 0.16 0.00 0.00 0.00 0.03 14.61 68% 1982 2.00 5.30 5.11 9.78 3.78 7.73 3.03 0.00 0.06 0.00 0.00 0.72 37.51 176% 1983 2.79 5.62 2.22 5.77 8.06 9.04 3.48 0.47 0.00 0.01 0.06 0.68 38.20 179% 1984 0.26 8.20 7.72 0.50 2.34 1.32 0.92 0.16 0.30 0.00 0.24 0.10 22.06 103% 1985 2.94 7.45 2.10 0.59 1.98 3.94 0.27 0.09 0.31 0.00 0.00 0.38 20.05 94% 1986 0.80 4.83 2.47 4.77 8.29 6.25 0.76 0.13 0.00 0.03 0.01 1.32 29.66 139% 1987 0.11 0.20 1.64 4.26 3.77 2.31 0.14 0.06 0.01 0.00 0.00 0.00 12.50 59% 1988 1.07 3.09 5.09 4.93 0.40 0.07 1.73 0.66 0.70 0.00 0.00 0.00 17.74 83% 1989 0.64 3.70 4.23 1.26 1.49 5.28 0.70 0.06 0.07 0.00 0.05 0.98 18.46 86% 1990 1.18 1.33 0.00 4.02 2.45 1.34 0.58 2.38 0.01 0.00 0.04 0.12 13.45 63% 1991 0.20 0.52 1.94 0.60 3.29 5.89 1.07 0.36 0.05 0.00 0.42 0.00 14.34 67% 1992 2.35 0.50 2.32 2.09 6.34 4.41 0.38 0.00 0.39 0.00 0.02 0.00 18.80 88% 1993 1.16 0.40 6.03 9.82 4.48 2.90 0.71 0.87 0.27 0.00 0.00 0.00 26.64 125% 1994 0.33 2.16 2.25 2.77 4.87 0.35 1.12 1.31 0.06 0.00 0.00 0.22 15.44 72% 1995 0.33 10.49 2.69 8.97 0.24 7.88 1.61 0.97 0.62 0.00 0.00 0.00 33.80 158% 1996 0.06 0.08 8.13 6.71 5.28 1.28 1.56 1.79 0.00 0.00 0.00 0.04 24.93 117% 1997 1.05 4.72 7.61 7.59 0.32 0.58 0.29 0.16 0.30 0.00 0.73 0.04 23.39 109% 1998 1.00 6.97 2.77 12.08 14.89 2.54 2.13 3.92 0.15 0.01 0.01 0.09 46.56 218% 1999 0.91 4.02 1.42 4.41 7.35 2.34 2.62 0.23 0.12 0.00 0.10 0.59 24.11 113% 2000 0.65 2.32 0.62 6.41 8.96 2.04 1.66 1.40 0.16 0.02 0.02 0.21 24.47 115% 2001 2.38 0.85 0.90 3.76 7.73 1.58 1.89 0.00 0.15 0.01 0.05 0.18 19.48 91% 2002 0.51 5.18 10.75 2.13 2.59 2.27 0.52 0.84 0.03 0.00 0.03 0.01 24.86 116% 2003 0.01 2.00 12.03 1.75 1.80 1.71 3.60 0.93 0.00 0.00 0.06 0.00 23.89 112% 2004 0.04 2.22 7.69 3.40 5.67 1.16 0.12 0.12 0.00 0.00 0.05 0.04 20.51 96% 2005 2.62 2.07 7.98 4.82 5.19 4.67 2.19 1.32 0.94 0.02 0.01 0.00 31.83 149% 2006 0.51 2.21 11.19 3.52 2.81 8.74 5.02 0.41 0.00 0.00 0.00 0.00 34.41 161% 2007 0.63 3.05 5.31 0.72 4.79 0.52 1.44 0.43 0.00 0.02 0.00 0.09 17.00 80% 2008 2.01 0.96 3.16 8.86 1.87 0.33 0.14 0.03 0.00 0.00 0.01 0.00 17.37 81% 2009 0.35 2.31 2.82 0.90 7.92 2.76 0.24 0.80 0.00 0.00 0.00 0.28 18.38 86% 2010 3.11 0.45 2.77 6.66 3.42 2.79 3.59 0.95 0.07 0.00 0.01 0.02 23.84 112% 2011 1.81 3.10 6.71 1.55 4.94 7.02 0.56 1.13 2.02 0.08 0.03 0.00 28.95 135% 2012 1.38 1.74 0.14 2.68 1.09 5.71 1.43 0.02 0.14 0.01 0.01 0.00 14.35 67% 2013 1.47 4.50 7.11 0.49 0.85 0.97 1.01 0.04 0.15 0.00 0.04 0.39 17.02 80% 2014 0.00 1.26 0.39 0.06 5.82 2.95 1.59 0.03 0.01 0.08 0.01 0.55 12.75 60% 2015 0.46 2.29 11.70 0.00 1.47 0.12 1.30 0.09 0.12 0.09 0.02 0.09 17.75 83% 2016 0.00 1.43 5.18 6.94 0.98 6.83 1.46 0.15 0.00 0.02 0.02 0.00 23.01 108% 2017 2.43 2.21 4.39 9.42 7.60 3.93 2.25 0.00 0.10 0.00 0.01 0.10 32.44 152% 2018 0.31 2.83 0.15 5.21 0.21 4.54 3.91 0.04 0.01 0.00 0.00 0.00 17.21 81% 2019 0.21 3.56 2.18 5.13 7.94 4.31 0.43 1.94 0.00 0.00 0.00 25.70 120% N 9 89 89 89 99 99 99 99 99 99 99 99 8 9 89 8
Averages
All years 1.07 2.66 4.06 4.32 3.74 3.03 1.51 0.53 0.16 0.02 0.05 0.19 21.37 100% 99% 6 1989-2018 1.00 2.60 4.68 4.32 4.22 3.18 1.56 0.69 0.20 0.01 0.06 0.13 22.65 106% 104% 5 1981-2010 1.07 3.12 4.44 4.63 4.48 3.29 1.46 0.70 0.16 0.00 0.06 0.20 23.61 110% 111% 6 All yrs min 0.00 0.00 0.00 0.00 0.04 0.03 0.00 0.00 0.00 0.00 0.00 0.00 8.16 38% 44% 2 All yrs max 5.51 10.49 12.03 12.08 14.89 9.04 5.47 4.02 2.02 0.73 0.80 2.06 46.56 218% 138% 14 125% 3
44% 2
97% 4
138% 5
80% 8
130% 12
82% 3
124% 2
69% 5
113% 5
16

SF precip stations monthly records v2.xlsx Tbl 9/9/2019 Table B-2
Monthly Rainfall, Downtown San Francisco NOAA Station, 1921-2019 water year:
sample date: 2/23/10 3/2/10 12/8/10 2/17/11 10/5/2011 a sample time: NR 6:30 10:05 11:05 NR 18:45 19:45 20:45
Analyte Units
pH 6.3d 6.6 6.8 8.1 7.4 7.0 6.9 6.8
Temperature °F 52d 56 54 62 62 53 53 53
Specific Conductance μmhos/cm 237d 224 197 113 160 209 238 244 900e Total Dissolved Solids mg/L 1 0 2 6 25 47 4 9 6 8 0 1 6 4 1 3 2 500e Turbidity NTU 49(4) 117 28.9 65.2 11 - - -
Total Suspended Solids mg/L 25 45 20 23 11 <7 7.0 16.5
Antimony μg/L < 0.5 < 0.5 < 0.5 < 0.5 <2.4 <0.5 <0.5 <0.5 dissolved h μg/L < 0.5 < 0.5 < 0.5 < 0.5 <2.4 <0.5 <0.5 <0.5 Arsenic μg/L < 2< 2< 2< 2 < 2 < 2 < 2 < 2
dissolved μg/L < 2< 2< 2< 23 . 7 J < 2 < 2 < 2
Barium μg/L 70.0 108 76.5 59.2 16.0 26.1 38.9 43.5
dissolved μg/L 50.1 61.1 61.0 32.8 8.2 24.4 34.7 39.5
Beryllium μg/L < 0.5 < 0.5 < 0.5 < 0.5 <0.24 <0.5 <0.5 <0.5 dissolved μg/L < 0.5 < 0.5 < 0.5 < 0.5 <0.24 <0.5 <0.5 <0.5 Cadmium μg/L < 0.25 < 0.25 < 0.25 < 0.25 <1 <0.25 <0.25 <0.25 dissolved μg/L < 0.25 < 0.25 < 0.25 < 0.25 <1 <0.25 <0.25 <0.25 Chromium μg/L 5.13 12.25 4.11 6.66 <1.5 1.67 4.26 4.83
dissolved μg/L 1.54 0.84 0.90 0.79 <1.5 1.35 3.34 3.55
Cobalt μg/L 1.10 2.64 0.87 1.34 <0.53 0.43 1.01 1.16
dissolved μg/L 0.16 0.08 0.19 0.13 <0.53 0.30 0.67 0.75 Copper μg/L 4.39 8.99 4.86 4.69 5.80 4.74 5.78 5.87
dissolved μg/L 4.32 2.40 3.52 1.40 4.2 J 4.37 5.49 5.52 Iron μg/L 1,387 3,624 1,426 2,440 110 382 1,159 1,240
dissolved μg/L 15.1 5.50 7.56 10.8 <7.2 262 826 849
Lead μg/L 0.64 1.59 0.61 0.91 <1.4 0.51 0.82 0.81
dissolved μg/L < 0.5 < 0.5 < 0.5 < 0.5 <1.4 <0.5 <0.5 <0.5 Manganese μg/L 51.2 144 41.9 66.2 19.0 18.6 37.7 39.7
dissolved μg/L 2.36 0.37 0.67 0.43 1.8 J 12.7 26.0 25.8 Mercury μg/L < 0.2 < 0.2 < 0.2 < 0.2 <0.036 <0.2 <0.2 <0.2 dissolved μg/L < 0.2 < 0.2 < 0.2 < 0.2 <0.036 <0.2 <0.2 <0.2 Molybdenum μg/L 0.46 0.34 0.31 0.23 <0.67 <0.35 0.66 0.63 dissolved μg/L 0.57 0.42 0.36 0.34 3.9 J <0.35 0.62 0.65 Nickel μg/L 7.57 18.54 5.59 10.3 <0.83 2.15 5.21 6.05
dissolved μg/L < 1 < 1 < 1 < 1 <0.83 1.72 3.78 4.09
Selenium μg/L < 2< 2< 2< 2 < 3 . 2 < 2 < 2 < 2
dissolved μg/L < 2< 2< 2< 24 . 5 J < 2 < 2 < 2
Silver μg/L < 0.25 < 0.25 < 0.25 < 0.25 <0.62 <0.25 <0.25 <0.25 dissolved μg/L < 0.25 < 0.25 < 0.25 < 0.25 <0.62 <0.25 <0.25 <0.25 Thallium μg/L < 1< 1< 1< 1 < 2 . 4 < 1 < 1 < 1
dissolved μg/L < 1< 1< 1< 1 < 2 . 4 < 1 < 1 < 1
Vanadium μg/L 3.70 8.83 3.29 4.23 6.40 5.52 4.49 4.38
dissolved μg/L 1.33 1.31 1.30 0.86 5.10 5.34 3.67 3.48
Zinc μg/L 31.4 32.3 21.3 27.1 180 124 86.2 74.2
dissolved μg/L 6.40 3.72 7.37 6.13 97 81.2 65.6 54.8
VOCs μg/L ND ND ND ND ND ND ND ND
Semi VOCs:

Bis-(2-ethylhexyl)-phthalate μg/L <0.3 0.41 J 1.05 0.76 J 29 57.3 3.97 <0.77 4 Exceeds environmental screening level. aNot in LIMS fMarine and groundwater screening levels.

Exceeds primary MCL. b"First flush" event. gCalifornia Dept. Public Health notification level.

Exceeds secondary MCL. cCalifornia MCL. hAll "disolved" samples were field filtered.

MCL Maximum Contaminant Level ND Not detected dUsed field duplicate value.

NR Not recorded J Qualified result eSecondary MCL. Samples collected and analyzed by SFPUC.

Table B-3
Results of Synthetic Turf Runoff or Leachate Sampling, South Sunset Playground, 2010-2012 2009-10
1/20/12 b
2011- 122010-11
6 MCLc
5 10
50g
5000e
300e
50e
1000
4 2
-
100
15 100e
50 50
1000d

3.1f
2 -
Tbls B-3 & B-4 Syn Turf Sampling results v2.xlsx 9/9/2019 3:57 PM water year:
sample date: 2/24/10 3/2/10 12/22/10 2/17/11 10/5/2011a sample time: NR 8:20 8:15 11:40 NR 6:35 7:30 8:40
Analyte Units
pH 7.2 7.1 7.78 7.5 7.5 7.0 7.0 7.2
Temperature °F 56 58 54 60 62 54 52 52
Specific Conductance μmhos/cm 382 390 304 228 330 648 374 373 900d Total Dissolved Solids mg/L 212 152 136 126 250 468 282 294 500d Turbidity NTU 14 32 1 3 . 8 1 3 - - -
Total Suspended Solids mg/L < 7 28.5 7.0 7.0 < 5 < 7 < 7 < 7 Antimony μg/L 0.67 0.70 0.59 0.54 < 2.4 0.52 0.67 0.70
dissolvedg μg/L 0.61 0.62 0.57 < 0.5 < 2.4 0.55 0.71 0.69 Arsenic μg/L < 2< 2< 2< 2 < 2 < 2< 2< 2
dissolved μg/L < 2< 2< 2< 2< 2 . 4< 2< 2< 2
Barium μg/L 56.7 138 59.2 56.1 120 196 65.5 80.7
dissolved μg/L 54.6 68.8 55.8 39.8 94.0 183 67.2 71.7
Beryllium μg/L < 0.5 < 0.5 < 0.5 < 0.5 < 0.24 < 0.5 < 0.5 < 0.5 dissolved μg/L < 0.5 < 0.5 < 0.5 < 0.5 < 0.24 < 0.5 < 0.5 < 0.5 Cadmium μg/L < 0.25 < 0.25 < 0.25 < 0.25 < 1.0 < 0.25 < 0.25 < 0.25 dissolved μg/L < 0.25 < 0.25 < 0.25 < 0.25 < 1.0 < 0.25 < 0.25 < 0.25 Chromium μg/L < 0.5 1.81 < 0.5 < 0.5 < 1.5 0.76 < 0.5 0.75 dissolved μg/L < 0.5 0.54 < 0.5 < 0.5 1.5 J 0.75 < 0.5 0.59 Cobalt μg/L 0.22 1.72 0.20 0.57 < 0.53 0.31 0.55 0.84
dissolved μg/L 0.22 0.18 0.16 0.19 1.1 J 0.31 0.55 0.58 Copper μg/L 5.48 8.91 5.70 5.75 26.0 12.0 14.4 15.8
dissolved μg/L 5.90 4.67 5.49 4.82 23.0 11.7 14.4 15.7
Iron μg/L 14.4 1,742 15.0 188 160 47.8 47.2 255
dissolved μg/L < 2.5 < 2.5 2.98 5.99 < 7.2 26.9 36.9 39.3 Lead μg/L < 0.5 1.69 < 0.5 < 0.5 < 1.4 < 0.5 < 0.5 < 0.5 dissolved μg/L < 0.5 < 0.5 < 0.5 < 0.5 < 1.4 < 0.5 < 0.5 < 0.5 Manganese μg/L 0.87 35.0 0.68 5.00 7.00 3.08 1.81 6.97
dissolved μg/L 1.87 0.53 0.30 1.50 2.6 J 1.88 1.73 3.87 Mercury μg/L < 0.2 < 0.2 < 0.2 < 0.2 0.38 < 0.2 < 0.2 < 0.2 dissolved μg/L < 0.2 < 0.2 < 0.2 < 0.2 0.28 < 0.2 < 0.2 < 0.2 Molybdenum μg/L 8.69 8.26 9.35 7.32 13.0 6.13 10.7 10.6 dissolved μg/L 8.44 7.37 9.51 7.83 11.0 6.17 10.6 10.0
Nickel μg/L 3.80 7.34 4.01 3.58 8.00 6.00 4.95 7.09
dissolved μg/L 3.64 3.89 3.78 2.53 6.20 5.79 4.97 6.05
Selenium μg/L < 2< 2< 2< 2< 3 . 2< 2< 2< 2
dissolved μg/L < 2< 2< 2< 28 . 7 J< 2< 2< 2
Silver μg/L < 0.25 < 0.25 < 0.25 < 0.25 < 6.2 < 0.25 < 0.25 < 0.25 dissolved μg/L < 0.25 < 0.25 < 0.25 < 0.25 < 6.2 < 0.25 < 0.25 < 0.25 Thallium μg/L < 1< 1< 1< 1< 3 . 0< 1< 1< 1
dissolved μg/L < 1< 1< 1< 1< 3 . 0< 1< 1< 1
Vanadium μg/L 1.60 6.52 1.62 2.07 5.70 4.68 1.53 2.45
dissolved μg/L 1.49 2.14 1.34 1.39 3.8 J 4.47 1.54 1.89 Zinc μg/L 58.5 137 51.6 41.0 82.0 140 46.6 104
dissolved μg/L 42.2 72.8 60.3 29.5 63.0 127.3 52.1 87.9 VOCs μg/L ND ND ND ND ND ND ND ND
Semi VOCs μg/L ND ND ND ND ND ND ND ND
Exceeds environmental screening level. aNot in LIMS eMarine and groundwater screening levels.

Exceeds secondary MCL. b"First flush" event. fCalifornia Dept. Public Health notification level.

MCL Maximum Contaminant Level ND Not detected cCalifornia MCL. gAll "disolved" samples were field filtered.

NR Not recorded J Qualified result dSecondary MCL. Samples collected and analyzed by SFPUC.

Table B-4
Results of Synthetic Turf Runoff or Leachate Sampling, Garfield Square Park, 2010-2012 2010-112009-10 2011-12
1/20/12b
50f
MCLc
50 1000d

3.1e
5 -
10 1000
4 6
5000d
300d
50d
50 2
-
100
15 100d
2 Tbls B-3 & B-4 Syn Turf Sampling results v2.xlsx 9/9/2019 3:57 PM Specific
Conduc-
tance
Total
Iron
Dis-
solved
Iron
Total
Manga-
nese
Dis-
solved
Manga-
nese
Bis-
(2-ethyl-
hexyl)-
phthalate
Dis-
solved
Copper
900 c 4 d 3.1 e
1 2/23-24/10 NR 71% - - 237 1,387 15.1 51 2.4 <0.3 4.3
2 3/2/10 6:30 78% 3 0.18 224 3,624 5.5 144 0.4 0.4 2.4
3 12/8/10 10:05 26% 4 0.14 197 1,426 7.6 42 0.7 1.1 3.5 5 2/17/11 11:05 68% 15 0.73 113 2,440 10.8 66 0.4 0.8 1.4 6 10/5/11
NR 2% - - 160 110 <7.2 19 1.8 29 4.2
7 18:45 29 0.85 209 382 262 19 13 57 4.4
19:45 30 0.94 238 1,159 826 38 26 4.0 5.5
20:45 31 1.07 244 1,240 849 40 26 <0.77 5.5
1 2/23-24/10 NR 75% - - 382 14 < 2.5 0.9 1.9 ND 5.9
2 3/2/10 8:20 78% 4 0.32 390 1,742 < 2.5 35 0.5 ND 4.7
4 12/22/10 8:15 44% 12 0.58 304 15 3.0 0.7 0.3 ND 5.5
5 2/17/11 11:40 68% 16 1.03 228 188 6.0 5.0 1.5 ND 4.8
6 10/5/11 NR 2% - - 330 160 < 7.2 7.0 2.6 ND 23
7 6:35 17 0.32 648 48 27 3.1 1.9 ND 12
7:30 18 0.34 374 47 37 1.8 1.7 ND 14
8:40 19 0.38 373 255 39 7.0 3.9 ND 16
a Water year (Oct-Sep) average approximately 21 inches. NR not recorded b Rainfall data for San Francisco Downtown, NOAA Station USW00023272. ND not detected c Secondary MCL; typically applied to dissolved concentrations. MCL maximum contaminant level d Primary MCL. bold exceeds standard
e Marine surface water and groundwater environmental screening level.

Storm
Event
South Sunset Playground
Garfield Square Park
300 c 50 c
1/20/12 17%
(μg/L)
Applicable Standards:

Sample Date
& Time
Approx.

Storm
Rainfall
Up to
Time of
Sample
(inches)b
17%1/20/12
Approx.

Storm
Duration
Up to
Time of
Sample
(hrs)
% Avg.

Water-
Year
Rainfall
thru
Prior
Daya,b
Table B-5
Summary of Water Quality Constituents with Elevated Concentrations Detected in Synthetic Turf Drainage at South Sunset Playground and Garfield Square Park Tbl B-5.xlsx Tbl B-1 (2) 9/17/2019
Rainfall data for San Francisco Downtown, NOAA Station USW00023272.

Both fields installed 2006-08
Monthly and Daily Rainfall Relative to Synthetic Turf Drainage Sample Dates, 2010-2012 Figure B-1
0%
20%
40%
60%
80%
100%
120%
140%

0.0 0.5

1.0 1.5

2.0 2.5
Jul-09
Aug-09
Aug-09
Oct-09
Oct-09
Dec-09
Dec-09
Jan-10
Mar-10
Apr-10
May-10
Jun-10
Jul-10
Aug-10
Sep-10
Oct-10
Nov-10
Dec-10
Dec-10
Jan-11
Mar-11
Apr-11
May-11
Jun-11
Jul-11
Aug-11
Sep-11
Oct-11
Nov-11
Dec-11
Jan-12
Jan-12
Mar-12
Apr-12
May-12
Jun-12
Cumulative % of Average Annual Rainfall
Daily Rainfall (in/day)
Daily Rainfall
Sample days
Cumulative % of avg annual
2009-2010 2010-2011 2011-2012
0 1
2 3
4 5
6 7
Jul-09
Aug-09
Sep-09
Oct-09
Nov-09
Dec-09
Jan-10
Feb-10
Mar-10
Apr-10
May-10
Jun-10
Jul-10
Aug-10
Sep-10
Oct-10
Nov-10
Dec-10
Jan-11
Feb-11
Mar-11
Apr-11
May-11
Jun-11
Jul-11
Aug-11
Sep-11
Oct-11
Nov-11
Dec-11
Jan-12
Feb-12
Mar-12
Apr-12
May-12
Monthly Rainfall (in/month)
Monthly RainfallSample month
Average
2009-2010
112% of avgerage
2011-2012
67% of average
2010-2011
125% of average
South Sunset
Playground
2/23/10 (time?)
3/2/2010 6:30
12/8/2010 10:05
2/17/2011 11:05
10/5/2011 (time?)
1/20/2012 18:45
1/20/2012 19:45
1/20/2012 20:45
Garfield Square
Park
2/24/2010 (time?)
3/2/2010 8:20
12/22/2010 8:15
2/17/2011 11:40
10/5/2011 (time?)
1/20/2012 6:35
1/20/2012 7:30
1/20/2012 8:40
Sample Dates & Times

0.00 0.05

0.10 0.15

0.20 12/8/10 0:00
2/8/10 12:00
12/9/10 0:00
Precipitation (inches/hour)
Event 3
Dec 8, 2010
Sample
10:05 AM

0.0 0.2

0.4 0.6

0.8 1.0
0:00 12:00 0:00
Precipitation (inches/hour)
Event 3
Dec 8, 2010
Sample
10:05 AM
Detections: a, d, f4 hrs

0.00 0.05

0.10 0.15

0.20 3/2/10 0:00
3/2/10 12:00
3/3/10 0:00
Event 2
March 2, 2010
Sample
6:30 AM

0.0 0.1

0.2 0.3

0.4 0.5
0:00 12:00 0:00
Cumulative Precipitation (inches/hour)
Event 2
March 2, 2010
Sample
6:30 AM
Detections:
a, c, d Detection Key:
a Total iron > 2ndary MCL
b Dissolved iron > 2ndary MCL
c Total manganese > 2ndary MCL
d Bis-(2-ethylhexyl)-phthalate < MCL
e Bis-(2-ethylhexyl)-phthalate > MCL
f Dissolved copper > environmental
screening levels for marine
surface water & groundwater.
3 hrs
Precipitation (inches/hour) Cumulative Precipitation (inches)

0.00 0.10

0.20 0.30
/19/12 12:00
1/20/12 0:00
/20/12 12:00
1/21/12 0:00
/21/12 12:00
Event 7
Jan 19-21, 2012
1/20/12
Samples
18:45
19:45
20:45

0.00 0.50

1.00 1.50

2.00 12:00 0:00 12:00 0:00 12:00
Cumulative Precipitation (inches/hour)
Event 7
Jan 19-21, 2012
1/20/12
Samples
18:45
19:45
20:45
Detections:
a, e, f
a, b, d, f
a, b, f
29-31 hrs
Precipitation (inches/hour) Cumulative Precipitation (inches)

0.00 0.05

0.10 0.15

0.20 10/4/11 12:00
10/5/11 0:00
10/5/11 12:00
Event 6
Oct 4-5, 2011
Time of 10/5/11
sample n/a

0.0 0.1

0.2 0.3

0.4 0.5

0.6 12:00 0:00 12:00
Event 6
Oct 4-5, 2011
Time of 10/5/11
sample n/a
Detections: e, f
Figure B-2
Hourly Rainfall During Storms When Synthetic Turf Drainage Sampled at South Sunset Playground Rainfall data for San Francisco Downtown, NOAA Station USW00023272.

Note differences in scale of axes.
n/a not available

0.00 0.05

0.10 0.15

0.20 2/23/10 0:00
23/10 12:00
2/24/10 0:00
24/10 12:00
2/25/10 0:00
Precipitation (inches/hour)
Event 1
Feb 23-24, 2010
Time of sample n/a

0.0 0.2

0.4 0.6

0.8 1.0

1.2 0:00 12:00 0:00 12:00 0:00
Cumulative Precipitation (inches)
Event 1
Feb 23-24, 2010
Time of sample n/a
Detections: a, c, f

0.00 0.10

0.20 0.30
2/16/11 12:00
2/17/11 0:00
2/17/11 12:00
2/18/11 0:00
Precipitation (inches/hour)
Event 5
Feb 16-17, 2011
Sample
11:05 AM

0.00 0.25

0.50 0.75

1.00 1.25
12:00 0:00 12:00 0:00
Cumulative Precipitation (inches)
Event 5
Feb 16-17, 2011
Sample
11:05 AM
Detections: a, c, d15 hrs

0.00 0.05

0.10 0.15

0.20 /21/10 12:00
2/22/10 0:00
/22/10 12:00
Precipitation (inches/hour)
Event 4
Dec 21-22, 2010
Sample
8:15 AM

0.0 0.1

0.2 0.3

0.4 0.5

0.6 12:00 0:00 12:00
Precipitation (inches/hour)
Event 4
Dec 21-22, 2010
Sample
8:15 AM
Detections: f
12 hrs

0.00 0.05

0.10 0.15

0.20 3/2/10 0:00
3/2/10 12:00
3/3/10 0:00
Event 2
March 2, 2010
Sample
8:20 AM

0.00 0.05

0.10 0.15

0.20 2/23/10 0:00
23/10 12:00
2/24/10 0:00
24/10 12:00
2/25/10 0:00
Precipitation (inches/hour)
Event 1
Feb 23-24, 2010
Time of sample n/a
Precipitation (inches/hour) Cumulative Precipitation (inches)

0.00 0.10

0.20 0.30
/19/12 12:00
1/20/12 0:00
/20/12 12:00
1/21/12 0:00
/21/12 12:00
Precipitation (inches/hour)
Event 7
Jan 19-20, 2012
1/20/12
Samples
6:35 AM
7:30 AM
8:40 AM

0.00 0.50

1.00 1.50

2.00 12:00 0:00 12:00 0:00 12:00
Cumulative Precipitation (inches/hour)
Event 7
Jan 19-20, 2012
Detections: f
17-19 hrs
1/20/12
Samples
6:35 AM
7:30 AM
8:40 AM
Precipitation (inches/hour) Cumulative Precipitation (inches)

0.0 0.1

0.2 0.3

0.4 0.5
0:00 12:00 0:00
Cumulative Precipitation (inches/hour)
Event 2
March 2, 2010
Sample
8:20 AM Detections: a, f
Detection Key:
a Total iron > 2ndary MCL
f Dissolved copper > environmental
screening levels for marine
surface water & groundwater.
4 hrs

0.0 0.2

0.4 0.6

0.8 1.0

1.2 0:00 12:00 0:00 12:00 0:00
Cumulative Precipitation (inches)
Event 1
Feb 23-24, 2010
Time of sample n/a
Detections: f

0.00 0.10

0.20 0.30
2/16/11 12:00
2/17/11 0:00
2/17/11 12:00
2/18/11 0:00
Precipitation (inches/hour)
Event 5
Feb 16-17, 2011
2/1711
Sample
11:40 AM

0.00 0.05

0.10 0.15

0.20 10/4/11 12:00
10/5/11 0:00
10/5/11 12:00
Event 6
Oct 4-5, 2011
Time of 10/5/11
sample n/a

0.00 0.25

0.50 0.75

1.00 1.25
12:00 0:00 12:00 0:00
Cumulative Precipitation (inches)
Event 5
Feb 16-17, 2011
2/17/11
Sample
11:40 AM
Detections: f
16 hrs

0.0 0.1

0.2 0.3

0.4 0.5

0.6 12:00 0:00 12:00
Event 6
Oct 4-5, 2011
Time of 10/5/11
sample n/a
Detections: f
Figure B-3
Hourly Rainfall During Storms When Synthetic Turf Drainage Sampled at Garfield Square Park Rainfall data for San Francisco Downtown, NOAA Station USW00023272.

Note differences in scale of axes.
n/a not available
Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

C-1

Appendix C: Review of Other Literature Related to Synthetic Turf This appendix provides the results of a search for literature pertaining to potential water quality impacts from synthetic turf. Twenty-three documents are listed chronologically and aspects relevant to groundwater are quoted or summarized. Many of the studies pertain to surface water and other above-ground exposures. Citations lacking a summary or quoted text indicate that little or no information relevant to groundwater impacts was found. 2006, An Assessment of Environmental Toxicity and Potential Contamination from Artificial Turf using Shredded or Crumb Rubber, Ardea Consulting, report by J.P. Sullivan prepared for Turfgrass Producers International, 43 p., March.
“The actual amount of contamination leaching from artificial turf used on playgrounds or athletic fields needs further research to determine the potential harm to human health or the environment… Tire chips should be used below the groundwater table only where higher levels of iron and manganese can be tolerated… In almost all studies, the iron level exceeded the Recommended Allowable Level… Iron is not an ingredient in rubber compounds. Its presence in some of the groundwater tests indicates that the steel belts and beads were not completely extracted during the tire recycling operation. Consideration should be given to establishing a maximum allowable steel content for recycled tire rubber… Because metals can be leached at low pH and organic compounds can be leached at high pH, unbound shredded tires should be used in environments where the soil and groundwater are at a fairly neutral pH.” 2008, A Review of Potential Health and Safety Risks from Synthetic Turf Fields Containing Crumb Rubber Infill, TRC, report prepared for New York City Department of Health and Mental Hygiene, 200 p., May.
2008, The Effects of Crumb Rubber on Water Quality, The Coastal Marine Resource Center, white paper by C. Graham for CMRC.org, NY, 9 p., September. 2008, Evaluation of the Environmental Effects of Synthetic Turf Athletic Fields, Milone & MacBroom, compendium of three white papers: (1) Thermal Effects Associated with Crumb Rubber In-filled Synthetic Turf Athletic Fields; (2) Evaluation of Benzothiazole, 4-(tert-octyl) Phenol and Volatile Nitrosamines in Air at Synthetic Turf Athletic Fields; (3) Evaluation of Stormwater Drainage from Synthetic Turf Athletic Fields, 46 p., December. 2009, An Assessment of Chemical Leaching, Releases to Air and Temperature at Crumb- Rubber Infilled Synthetic Turf Fields, New York State Department of Environmental Conservation and Health, report by L. Lima and R. Walker, 140 p., May. http://www.dec.ny.gov/docs/materials_minerals_pdf/crumbrubfr.pdf “The objectives of the groundwater survey were to collect samples from downgradient wells at existing synthetic turf fields and to measure the concentrations of SVOCs that may leach from the crumb rubber. The concentrations of these compounds were compared to the NYS Groundwater Quality Standards (NYSDEC 1998b). To obtain samples in a timely manner, the Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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C-2

survey focused on areas where sandy soil is predominant. In 2008, four turf fields were selected ranging from less than 1 to 7 years old… Two to three downgradient wells were installed at each field and samples were collected at various depths… The thirty-two groundwater samples at these sites have a depth to the groundwater table ranging from 8.3 ft to 70 ft… Based on test results of 32 groundwater samples, no organics or zinc were detected at the turf fields… Application of the dilution-attenuation factor (DAF) to the leachate results in this study demonstrates that crumb rubber can be used as an infill without significant impact on groundwater quality.”
“Highly varied concentrations of chemicals and metals were found in samples from within each artificial turf field tested… Results indicated that significant concentrations of zinc, aniline, phenol and benzo-thiazole (BZT) were leaching from the [crumb rubber]. “Groundwater test results at the two artificial turf fields targeted for this survey identified no chemicals or metals in groundwater. However, the groundwater was collected from deep wells and researchers noted that they would perform additional testing at more shallow depths in the future to better characterize the potential risk… The study cautioned that sufficient distance and soil barriers must be placed between the contaminating synthetic turf fields and groundwater in order to protect public health.
“As leachate moves through soil to the groundwater table, contaminant concentrations are attenuated by adsorption and degradation, and further reduced by dilution when contaminants are mixed with groundwater. An analysis of attenuation and dilution mechanisms and the associated reduction factors indicates that crumb rubber may be used as an infill without significant impact on ground- water quality, assuming the limitations of mechanisms, such as separation distance to groundwater table, are addressed.”
2010, Field, Pilot, and Laboratory Studies for the Assessment of Water Quality Impacts of Artificial Turf, Cheng, H., and Reinhard, M., Dept. Civil and Environmental Engineering, Stanford University, report prepared for Santa Clara Valley Water District, 100 p., June. “An exploratory study commissioned by Santa Clara Valley Water District (SCVWD) found heavy metals (barium, chromium, copper, and particularly, zinc) and organic compounds (benzoic acid and phenol) leaching from two artificial turfs (from two different manufacturers) using the Toxicity Characteristic Leaching Procedure (TCLP). Benzoic acid and phenol are deemed of lesser concern because they can be photochemically or biologically degraded. Thus, in surface and groundwater, relatively effective natural attenuation of these contaminants can be expected. Results of the TCLP study are difficult to extrapolate to environmental conditions because conditions were far more aggressive than those encountered in the environment.” 2010, Artificial Turf Study, Leachate and Stormwater Characteristics, Connecticut Department of Environmental P
rotection (DEP), 24 p., July.
“This study did not identify any significant risks to groundwater protection criteria in the stormwater runoff from artificial turf fields. It is important to note, that the DEP study did not Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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C-3

directly collect and analyze groundwater at these artificial turf fields. Consequently, this conclusion regarding consistency with groundwater protection criteria is an extrapolation of the stormwater results collected and the evaluation of data presented in recent studies.” 2011, Effectiveness of Field Turf Artificial Turf for Management of Stormwater, AKRF, Inc and D. S. Thaler and Associates, report prepared for Field Turf, 22 p., June. “A study of four artificial turf fields in Connecticut (Connecticut Department of Environmental Protection, 2010) found that zinc leaching from artificial turf fields was a potential risk to surface waters, but in evaluating the potential risks of stormwater runoff the study goes on to state that, ‘Since the mean concentration of zinc in the stormwater samples is below surface water protection criteria, the discharge from the artificial turf fields to groundwater is intermittent, and zinc is immobilized in soils by adsorption, absorption and precipitation, the potential for impacts to surface waters being recharged by this groundwater is minimal.’ A recent Montgomery County, Maryland report (Montgomery County Staff Work Group, 2011) reported that samples obtained from an on-going San Francisco Public Utilities synthetic turf monitoring study showed total zinc levels above the Maryland Toxic Substances Criteria for Ambient Surface Waters (120 µg/l) standard but showed dissolved zinc levels below the acute toxicity level.”
2011, Human Health Risk Assessment of Synthetic Turf Fields Based Upon Investigation of Five Fields in Connecticut, Ginsberg, G., Toal, B., Simcox, N., Bracker, A., Golembiewski, B., and Kurland, T., Hedman, C., Journal Toxicol Environ Health, v. 74, n. 17, pp. 1150-74. “The study demonstrated that for the products and fields we tested, exposure to infill and artificial turf was generally considered de minimus, with the possible exception of lead for some fields and materials.”
2011, Nature Grass vs Synthetic Turf Report, Department of Local Government, Sport and Cultural Industries, Chapter 7, Broader Environmental Considerations, Government of Western Australia.
2014, Bio-Accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers, Pavilonis, B.T., Weisel, C.P., Buckley, B., and Lioy, P.J., Risk Analysis, v. 34, n. 1, pp. 44-55, January.
2014, Environmental and Health Impacts of Artificial Turf: A Review, Cheng, H., Hu, Y., and Reinhard, M., Environmental Science and Technology, v. 48, n. 4, pp. 2114-2132, January. “A number of field studies have been conducted to investigate the impact of tire shreds and chips used in civil engineering applications on the quality of surface water and groundwater through sampling of existing sites and field trials with follow-up monitoring of up to 2 years. In general, Fe, Mn, Zn, and Al appeared to be the major contaminants of concern even though their concentratio
ns did not exceed the respective maximum contaminant levels (MCLs) for drinking water in most cases, while the organic contaminants (e.g., amines, aniline, quinoline, amides, and Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

C-4

benzothiazole) occurred only at trace levels. These results suggest that scrap tire materials may affect surface water and/or groundwater and warrant further field study with controls. “Even though leachate from tire chips and tire rubber crumb can be toxic to some aquatic life, dilution (i.e., by infiltrating rainwater and groundwater) in natural systems is expected to reduce its toxicity and lower the associated ecological risk.
“A limited number of studies have shown that the concentrations of volatile and semi-volatile organic compounds in the air above artificial turf fields were typically not higher than the local background, while the concentrations of heavy metals and organic contaminants in the field drainages were generally below the respective regulatory limits.” 2014, Artificial Turf, Santa Clara Valley Water District, fact sheet, publication 503, March, 1 p. 2015, Science May Get Sidelined in Artificial Turf Debate, Mole, B., Science News, https://www.sciencenews.org/blog/growth-curve/science-may-get-sidelined-artificial-turf-debate, 3 p., April.
2015, Consideration of Artificial Turf Pilot Study: Follow-up to Questions Raised at June 23, 2015 Board Meeting, East Bay Municipal Utilities District, presentation to Board of Directors, 10 p., July.
2015, Leaching of Dissolved Organic Carbon, Dissolved Nitrogen, and Inorganic Constituents from Scrap Tires, Selbes, M., Yilmaz, O., Khan, A.A., and Karanfil, T., Chemosphere, v. 139, November, http://www.sciencedirect.com/science/article/pii/S004565351500082X. “This study offers no confirmation that synthetic turf fields are safe… The results of testing suggest that exposure to acidic rainwater or groundwater may increase the rates at which dissolved organic carbon and some inorganic compounds leach from crumb rubber infill. The study also found rapid initial leaching rates for compounds they measured… While these rates may drop to a constant level over time, this observation raises a health concern about an increased risk of exposures, especially to children, from new fields and playgrounds containing recycled rubber infill and mulch, as well as from fields and playgrounds that are routinely refilled to replenish the surface cushion because of infill and mulch migrating due to use and weather. Finally, the identification of lead in all samples observed in this study is of great concern.”
2016, Understanding Rainfall and Drainage in Synthetic Turf Systems, Brock International, presentation to ASBA, 31 p., January.
2016, Ordinance Amending Section 17.612.010 of the Sacramento City Code Relating to Landscape Requirements and the Use of Artificial Turf City of Sacramento, Community Development Department, City Council Report, 14 p., December.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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2017, Synthetic Turf Industry’s Claims Versus the Science: A Careful Analysis of Studies that Industry Uses to Justify Safety Claims, Environment & Human Health, Inc., report, 112 p. 2018, Comprehensive Multipathway Risk Assessment of Chemicals Associated with Recycled ("Crumb") Rubber in Synthetic Turf Fields, Peterson, M.K., Lemay, J.C., Shubin, P., and Prueitt, R.L., Environmental Research, v. 160, pp. 256-268. “…results add to the growing body of literature that suggests recycled rubber infill in synthetic turf poses negligible risks to human health.”
2019, Synthetic Turf Field Recycled Tire Crumb Rubber Research Under the Federal Research Action Plan, USEPA/ORD and Centers for Disease Control and Prevention Agency for Toxic Substances and Disease Registry and, Final Report Part 1–Tire Crumb Rubber Characterization Appendices, Volume 2, 456 p., July.
2019, Synthetic Turf News, California Office of Environmental Health Hazard Assessment (OEHHA), https://oehha.ca.gov/risk-assessment/synthetic-turf-studies. 2019, Synthetic Turf Health and Environmental Impacts, Center for Sports Surface Research, Penn State College of Agricultural Sciences, bibliography, https://plantscience.psu.edu/research/centers/ssrc/research/synthetic-turf-health.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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Appendix D: References
AKRF, Inc and D. S. Thaler and Associates, 2011, Effectiveness of Field Turf Artificial Turf for Management of Stormwater, report prepared for Field Turf, 22 p., June.

Ardea Consulting, 2006, An Assessment of Environmental Toxicity and Potential Contamination from Artificial Turf using Shredded or Crumb Rubber, report by J.P. Sullivan prepared for Turfgrass Producers International, 43 p., March.

Brock International, 2016, Understanding Rainfall and Drainage in Synthetic Turf Systems, presentation to ASBA, 31 p., January.

California Office of Environmental Health Hazard Assessment (OEHHA), 2019, Synthetic Turf News.

Center for Sports Surface Research, Penn State College of Agricultural Sciences, 2019, Synthetic Turf Health and Environmental Impacts, bibliography.

Cheng, H., and Reinhard, M., 2010, Field, Pilot, and Laboratory Studies for the Assessment of Water Quality Impacts of Artificial Turf, Dept. Civil and Environmental Engineering, Stanford University, report prepared for Santa Clara Valley Water District, 100 p., June.

Cheng, H., Hu, Y., and Reinhard, M., 2014, Environmental and Health Impacts of Artificial Turf:

A Review, Environmental Science and Technology, v. 48, n. 4, pp. 2114-2132, January.

Community Development Department, 2016, Ordinance Amending Section 17.612.010 of the Sacramento City Code Relating to Landscape Requirements and the Use of Artificial Turf City of Sacramento, City Council Report, 14 p., December.

Connecticut Department of Environmental Protection, 2010, Artificial Turf Study, Leachate and Stormwater Characteristics, 24 p., July.

David Teter Consulting, 2013, Environmental Testing Protocols for the Procurement of Synthetic Turf Products, prepared for SFRPD, August.

Department of Local Government, Sport and Cultural Industries, Government of Western Australia, 2011, Nature Grass vs Synthetic Turf Report, Chapter 7, Broader Environmental Considerations.

East Bay Municipal Utilities District, 2015, Consideration of Artificial Turf Pilot Study: Follow- up to Questions Raised at June 23, 2015 Board Meeting, presentation to Board of Directors, 10 p., July.

Environment & Human Health, Inc., 2017, Synthetic Turf Industry’s Claims Versus the Science:

A Careful Analysis of Studies that Industry Uses to Justify Safety Claims, report, 112 p.

Fall Creek Engineering, 2011, Evaluation of Alternative Stormwater Management Systems, Beach Chalet, San Francisco, California, letter report prepared for Verde Design, Inc., February.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
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D-2

Ginsberg, G., Toal, B., Simcox, N., Bracker, A., Golembiewski, B., Kurland, T., and Hedman, C., 2011, Human Health Risk Assessment of Synthetic Turf Fields Based Upon Investigation of Five Fields in Connecticut, Journal Toxicol Environ Health, v. 74, n. 17, pp. 1150-74.

Milone & MacBroom, 2008, Evaluation of the Environmental Effects of Synthetic Turf Athletic Fields, compendium of three white papers, 46 p., December.

Mole, B., 2015, Science May Get Sidelined in Artificial Turf Debate, Science News, April, 3 p.

New York State Department of Environmental Conservation, 2009, An Assessment of Chemical Leaching, Releases to Air and Temperature at Crumb-Rubber Infilled Synthetic Turf Fields, report prepared by Lima, L., and Walker, R., 140 p., May.

Pavilonis, B.T., Weisel, C.P., Buckley, B., and Lioy, P.J., 2014, Bio-Accessibility and Risk of Exposure to Metals and SVOCs in Artificial Turf Field Fill Materials and Fibers, Risk Analysis, v. 34, n. 1, pp. 44-55, January.

Peterson, M.K., Lemay, J.C., Shubin, P., and Prueitt, R.L., 2018, Comprehensive Multipathway Risk Assessment of Chemicals Associated with Recycled ("Crumb") Rubber in Synthetic Turf Fields, Environmental Research, v. 160, pp. 256-268.

San Francisco Stormwater Management Requirements and Design Guidelines team, 2016, Stormwater Management Requirements, brochure, May.

Santa Clara Valley Water District, 2014, Artificial Turf, fact sheet, publication 503, 1 p., March.

Selbes, M., Yilmaz, O., Khan, A.A., and Karanfil, T., 2015, Leaching of DOC [Dissolved Organic Carbon], DN [Dissolved Nitrogen] and Inorganic Constituents from Scrap Tires, Chemosphere, v. 139, November.

SFBEM, 2014, San Francisco State University Recreation Wellness Center Project Meeting December 3, 2013, letter to W. Bloom/SFSU from I. Torrey, January.

SFDPW, 2016, Stormwater Management Ordinance, April.

SFPRD, 2009, Award of Contract to Renovate Kimbell Playground Athletic Field, letter to Recreation and Park Commission, July.

SFPUC WRD & USF, 2018, USF Benedetti Baseball Field Groundwater Infiltration of Artificial Turf Runoff, email discussion, November.

SFPUC WW, WC, & WRD, 2018, Artificial Turf Policies, email discussion, July.

SFPUC WWE & WE, 2015, Artificial Turf Policy Discussion Meeting Minutes, March.

SFPUC, 2010-2012, Analytical results, South Sunset Playground and Garfield Square Park synthetic turf infiltration samples.

SFPUC, 2011, First Flush Synthetic Turf Stormwater Quality Monitoring and Sampling Plan, prepared by B. Eagon and S. Rhodes, May.

Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection
September 19, 2019

D-3

SFPUC, 2013, Draft Synthetic Turf Requirements for the Large Landscape Grant Program, prepared by A. Dougherty, J. Gilman, and K. Kortkamp/WWE, July.

SFPUC, 2014, Position on Artificial Turf, email from J. Ortiz/WC, March.

SFPUC, 2015, Artificial Turf Policy Discussion between WWE and WE, meeting minutes, March.

SFPUC, 2015, USF Benedetti Baseball Field, email from J. Gilman, February.

SFPUC, 2018, Artificial Turf Policy Discussion, email correspondence between K. Kortkamp, J.

Scarpulla, and J. Ortiz, July.

SFRPD & SFPUC, 2010, Beach Chalet Field Renovation Project Synthetic Turf Stormwater Discussion, prepared by B. Eagon, May.

SFRPD & SFPUC, 2010, Synthetic Turf Stormwater Quality Monitoring and Sampling Plan, prepared by B. Eagon, February.

SFRPD, 2008, Findings and Department Recommendations, Synthetic Playfields Task Force, Appendix D: Use of Synthetic Turf on San Francisco Playfields, August.

SFSU and CCSF, 2013, Recreation Wellness Center Coordination Meeting Notes, December.

The Coastal Marine Resource Center, 2008, The Effects of Crumb Rubber on Water Quality, white paper by C. Graham for CMRC.org, NY, 9 p., September.

TRC, 2008, A Review of the Potential Health and Safety Risks from Synthetic Turf Fields Containing Crumb Rubber Infill, report prepared for New York City Department of Health and Mental Hygiene, 200 p., May.

URS, 2013, Agenda Package for Recreation Wellness Center Coordination Meeting, prepared by A. Sansevero, December. (includes Project Description)
URS, 2014, Design Options Related to Artificial Turf, SF State Recreation Wellness Center Project, prepared by A. Sansevero for SFPUC meeting, January.

USEPA/ORD and Centers for Disease Control and Prevention Agency for Toxic Substances and Disease Registry, 2019, Synthetic Turf Field Recycled Tire Crumb Rubber Research Under the Federal Research Action Plan, Final Report Part 1–Tire Crumb Rubber Characterization Appendices, Volume 2, 456 p., July.

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Robert Hall
To: [email protected]
Cc: Commission; Recpark Commission
Subject: Request for Coastal Zone Review of Synthetic Turf Expansion Adjacent to Groundwater Recharge Areas Date: Monday, November 3, 2025 3:08:51 PM
Attachments: Draft memo on SF policy synthetic turf drainage and GW quality protection 190919.pdf Groundwater protection letter.pdf
Dear Commissioners and Staff,
I am bringing forward a groundwater protection issue relevant to coastal zone management.

The SFPUC has not yet finalized its groundwater protection policy for synthetic turf drainage, and past monitoring has documented exceedances of drinking water standards during storm events.

I respectfully request that the Coastal Commission request confirmation of groundwater protection compliance before any new or expanded artificial turf installations proceed in coastal-relevant hydrological zones.

Full letter follows below.

In solidarity,
Bob Hall
Keep Crocker Real
Please note the groundwater vulnerability of the Westside Basin and request confirmation of groundwater protection compliance before any coastal zone artificial turf expansion proceeds.

Re: Request for Updated Policy and Sampling Plan for Synthetic Turf Field Drainage and Groundwater Protection
I am writing to request that the San Francisco Public Utilities Commission (SFPUC) complete and release an updated policy governing stormwater drainage from synthetic turf athletic fields and their potential impacts to groundwater, building upon the Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection dated September 19, 2019.

The 2019 draft review noted that, despite widespread use of synthetic turf systems in the City, past monitoring data were not fully interpreted and consensus policy remains unresolved, especially concerning infiltration in the Westside Groundwater Basin.

Now, with additional turf installations proposed, including large expansion at Crocker Amazon Park, it is critical that SFPUC complete this analysis before further synthetic turf construction proceeds.

Summary of Past Monitoring Findings (2010–2012)
SFPUC sampling at South Sunset Playground and Garfield Square Park found:

Dissolved iron and manganese exceeding secondary drinking water standards during early-season rainfall.

Bis-(2-ethylhexyl)-phthalate, a plasticizer from synthetic rubber infill, above its 4 µg/L MCL in multiple events.

Dissolved copper exceeding screening levels for groundwater and surface water.

These exceedances occurred four-plus years after installation, indicating ongoing material breakdown and leaching, not temporary startup conditions.

Recent Findings and Data Gaps
Stormwater sampling at Beach Chalet in 2024 has not yet been publicly interpreted against groundwater protection criteria, and 2025 internal discussions referenced concern regarding chromium levels. This indicates the need for updated analysis.

Need to Evaluate PFAS and Microplastics
Since the 2010–2012 sampling program, research has increasingly identified PFAS (per- and polyfluoroalkyl substances) and microplastics as contaminants associated with synthetic turf fibers, infill, and backing materials. PFAS are now subject to enforceable U.S. EPA drinking water standards, and microplastics have been documented in Bay and watershed stormwater pathways.

Because the City’s synthetic turf fields function as exposed plastic surfaces that degrade under UV, abrasion, and weathering, it is both scientifically and regulatorily appropriate that the next round of evaluation:

Test stormwater drainage for PFAS compounds, including PFOS, PFOA, PFHxS, PFNA, and polymeric PFAS used in plastic turf coatings; and
Quantify microplastic particle shedding, including infill granules and synthetic blade fragments.

Monitoring these contaminants is essential for groundwater protection planning.

Requests
I respectfully request that SFPUC:

1. Finalize and publicly release a synthetic turf groundwater protection policy;

2. Complete and publish interpretation of the 2010–2012 monitoring data;

3. Analyze and release results from 2024–2025 Beach Chalet sampling;

4. Include PFAS and microplastics sampling and reporting in all future synthetic turf drainage evaluations;

5. Establish ongoing seasonal first-flush monitoring for synthetic turf fields;

6. Disclose leaching profiles of alternative turf and infill materials; and

7. Enact a pause on new or expanded synthetic turf installations, including the proposed expansion at Crocker Amazon Park, which is adjacent to and hydrologically connected to the SFPUC Amazon Reservoir and groundwater recharge zone, until updated policy and monitoring frameworks are in place.

Conclusion
SFPUC’s stewardship of the Westside Groundwater Basin is critical to San Francisco’s long- term water resiliency. Finalizing this policy now will provide clarity for City agencies, ensure environmental health protections, and maintain public confidence in groundwater safeguarding.

Thank you for your consideration.

Sincerely,
Bob Hall
Keep Crocker Real
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Robert Hall
To: [email protected]; Jue, Tyrone (ENV); Ojea, Pauli (ENV) Cc: Commission; Recpark Commission
Subject: Request for SFE Coordination on PFAS and Microplastics Monitoring from Synthetic Turf Installations Date: Monday, November 3, 2025 3:18:56 PM
Attachments: Groundwater protection letter.pdf
Draft memo on SF policy synthetic turf drainage and GW quality protection 190919.pdf Hello SF Environment Staff and Commission Members,
I am requesting that the San Francisco Environment Department support interagency coordination to ensure that synthetic turf installations are evaluated for PFAS and microplastic release, consistent with emerging science and state regulatory direction.

The City currently has no finalized cross-departmental policy for evaluating these contaminants in synthetic turf drainage, despite synthetic fields being actively installed and expanded. This gap places both water quality and environmental health at risk.

Please see the letter below for detailed background and specific requests.

Warm regards,
Bob Hall
Keep Crocker Real
Please coordinate interdepartmental review and incorporate PFAS + microplastics considerations into the City’s materials and resilience policies.

Re: Request for Updated Policy and Sampling Plan for Synthetic Turf Field Drainage and Groundwater Protection
I am writing to request that the San Francisco Public Utilities Commission (SFPUC) complete and release an updated policy governing stormwater drainage from synthetic turf athletic fields and their potential impacts to groundwater, building upon the Draft Review of San Francisco Policies Related to Synthetic Turf Field Drainage and Groundwater Quality Protection dated September 19, 2019.

The 2019 draft review noted that, despite widespread use of synthetic turf systems in the City, past monitoring data were not fully interpreted and consensus policy remains unresolved, especially concerning infiltration in the Westside Groundwater Basin.

Now, with additional turf installations proposed, including large expansion at Crocker Amazon Park, it is critical that SFPUC complete this analysis before further synthetic turf construction proceeds.

Summary of Past Monitoring Findings (2010–2012)
SFPUC sampling at South Sunset Playground and Garfield Square Park found:

Dissolved iron and manganese exceeding secondary drinking water standards during early-season rainfall.

Bis-(2-ethylhexyl)-phthalate, a plasticizer from synthetic rubber infill, above its 4 µg/L MCL in multiple events.

Dissolved copper exceeding screening levels for groundwater and surface water.

These exceedances occurred four-plus years after installation, indicating ongoing material breakdown and leaching, not temporary startup conditions.

Recent Findings and Data Gaps
Stormwater sampling at Beach Chalet in 2024 has not yet been publicly interpreted against groundwater protection criteria, and 2025 internal discussions referenced concern regarding chromium levels. This indicates the need for updated analysis.

Need to Evaluate PFAS and Microplastics
Since the 2010–2012 sampling program, research has increasingly identified PFAS (per- and polyfluoroalkyl substances) and microplastics as contaminants associated with synthetic turf fibers, infill, and backing materials. PFAS are now subject to enforceable U.S. EPA drinking water standards, and microplastics have been documented in Bay and watershed stormwater pathways.

Because the City’s synthetic turf fields function as exposed plastic surfaces that degrade under UV, abrasion, and weathering, it is both scientifically and regulatorily appropriate that the next round of evaluation:

Test stormwater drainage for PFAS compounds, including PFOS, PFOA, PFHxS, PFNA, and polymeric PFAS used in plastic turf coatings; and
Quantify microplastic particle shedding, including infill granules and synthetic blade fragments.

Monitoring these contaminants is essential for groundwater protection planning.

Requests
I respectfully request that SFPUC:

1. Finalize and publicly release a synthetic turf groundwater protection policy;

2. Complete and publish interpretation of the 2010–2012 monitoring data;

3. Analyze and release results from 2024–2025 Beach Chalet sampling;

4. Include PFAS and microplastics sampling and reporting in all future synthetic turf drainage evaluations;

5. Establish ongoing seasonal first-flush monitoring for synthetic turf fields;

6. Disclose leaching profiles of alternative turf and infill materials; and

7. Enact a pause on new or expanded synthetic turf installations, including the proposed expansion at Crocker Amazon Park, which is adjacent to and hydrologically connected to the SFPUC Amazon Reservoir and groundwater recharge zone, until updated policy and monitoring frameworks are in place.

Conclusion
SFPUC’s stewardship of the Westside Groundwater Basin is critical to San Francisco’s long- term water resiliency. Finalizing this policy now will provide clarity for City agencies, ensure environmental health protections, and maintain public confidence in groundwater safeguarding.

Thank you for your consideration.

Sincerely,
Bob Hall
Keep Crocker Real
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender.

Report Suspicious ‌
From: slm frontstoop.com
To: Commission
Subject: Survey follow up comment
Date: Tuesday, November 4, 2025 10:33:39 AM
Hi SFPUC, I'm an SFPUC customer.

I just did the survey on the 9% proposed rate increases year over year. Of course, the survey doesn't say or remind us for how many years.

I am not against rate increases.

I AM AGAINST 9% annual rate increases for who knows how many years. We also all know that you think 9% goes down easier then 10%. It doesn't. 9% is as close as you can get to 10% without being 10%.
9% for a first year of a multi year rate increase can be acceptable, but the rate increase has to decline if it's going to be a multi year rate increase.

I give your survey a C grade. The attempted strategic manipulation was too obvious.

Sandra Lee Messer

This Message Is From an External Sender
This message came from outside your organization.

Report Suspicious ‌
From: Francisco Da Costa
To: Lennear, Tiffany; Francisco Da Costa; joe king; Greg Wagner; Stone, Claire (CON); Joyce Iulio-Sua; Larry Stringer; Ritchie, Steve
Subject: Please circulate this letter - linked to Joe King, Conrad King, Adolfo Padilla.

Date: Thursday, November 13, 2025 10:06:34 AM
Tiffany Lennear:

Please circulate this letter to the SF Public Utilities Commissioners and to the General Manager (SFPUC) - and all the Managers at San Francisco Public Utilities Commission SFPUC. Also to the SF City Attorney, the SF Controller, and the Mayor of SF.

I have spoken twice before the SFPUC and I should have gotten a reply but I see the cowards are so pathetic that they cannot even reply to my letter.

The SFPUC Commissioners have no clue what is happening - Joe King has gone out of his way to create a team to clean up the many Reservoirs we have in San Francisco. For example the University Mound Reservoir need cleaning and there is no Safety Protocol in place - Steve Richie is busy pussying footing talking about the Hetch Hetchy Reservisor - lying and hooding us all in broad daylight.

Joe King took upon himself to create a team to address Safety Issues linked to the cleaning and maintaining of the many Reservoirs.

Joe King took upon himself to send Adolfo Padilla to get training to address all the many issues linked to Confined Space Training - our Reservoirs here in San Francisco are not maintained. In fact there is no protocol if some emergency issues break out. Steve Richie has not addressed nor does
he understand Safety Issues and the need for Confined Space training.

It is the same with the many wells or cisterns we have - very little maintaining and no Standard Operating Procedures in place.

The issue of Safety and Over time was addressed by Joe King to William Teahan and others to maintain standards and have a plan and protocol
to address any major issues linked to cleaning the reservoirs and maintaining our reservoirs.

Before Joe King took charge Frank Jordan did not address the issues of Confined Space training and wanted to use laborers and those managing traffic holding signs - actions that do not do justice to standard and maintaining our reservoirs.

Joe King sent Adolfo Padilla to the " Confined Space Training " - and shared the information to his team and Supervisor Joe King - for this dialogue the team and Joe King created a protocol and brought the plan to William Teahan and Steve Richie - both corrupt who should be brought to book.

Instead of supporting Joe King and Adolfo Padilla - the Managers did not want to spend money to do right - and prefered to put the workers in harm's way.

Joy Chen had no business moving Adolfo Paddilla from one job to another - for example Adolfo Paddilla was sent to help the Arborists - Adolfo, had no training - and while working with the Arborists he fell from the three and got hurt.

Adolfo Paddilla is due for an operation in a month or so and again - he will have to be out of pocket and his health benefits have been denied him - someone called Blue Shield to cancel his health benefits - could it be Joy Chen?
Lilly Pricado, a plumber, was killed - she worked for the SFPUC - there were several articles about her death.

To date no one has bothered to deal with Safety and our SFPUC workers are treated with disdain by folks like Steve Richie and William Teahan who have to be fired - William Teahan was found years ago - watching porno while at work. Why is he still working? Who is backing these unfit and uncouth workers? Anyway you look at the dismissal of Joe King, Conrad King, and Adolfo Padilla - you see a pattern where rules and regulations are not adhered to by the Managers. ,
Joe King, Conrad King and Adolfo Padilla have been targeted - retaliated against because they have each worked hard and brought to the attention of Management the utter failure on all levels and in this case Safety and Frank Jordan failing to follow standards - case in point Safety and Confined Space training.

Joe King is a hard worker and for eight years he was honored, respected and his working record was excellent.

It is the same with Adolfo Padilla who worked very hard for over six years - and was honored with many commendations.

Conrad King, the son of Joe King, worked for three months - and was very happy to work and worked hard - learning from his father.

The SFPUC managers - corrupt to the core - surrounding Joe King and Adolfo Padilla, were ganged upon and retaliated.

Lies, false statements, Chen from HR forcing the workers to lie, Joy Chen fabricated false statements - leading to fake terminations - shame on SFPUC.

The Managers who called Joe King and Adolfo Padilla to their offices - lied,falsified information - and threatened Joe King and Adolfo Padilla.

The Managers went too far to accuse Joe King of sexual violence and as I mention earlier violence in the work place.

The Managed without permission accessed information from the computer and surprised Joe King by revealing information that no one was supposed
to have access to - health information and some other sensitive information.

Charges fabricated against hard working - shame on the Managers who have failed as leaders and managers - and must be brought to book.

Adolfo Padilla took his daughter to the hospital to attend to an emergency - he had paid his dues to Blue Shield - he was in good standing.

Someone from SFPUC HR - called Blue Shield and had Adoldo Padilla health benefits cancelled.

Whoever called Blue Shield must be brought to book and fired.

Get rid of the cancer - and utter nonsense that is tolerated - harassing hard working workers.

Imagine the child needing medical help and forcing Adolfo Padilla to another clinic and paying for the treatment with his own money - in spite of paying his dues to Blue Shield.

Joy Chen has been playing with fire - bringing workers together - and forcing them to lie against Joe King and Adolfo Padilla.

What right did Joy Chen have to assign Adolfo Padilla from job to job - when he was a hard worker - honored the employee of the year.

Both Joe King and Adolfo Padilla are decent human beings - ethical and men that are respected - again and again the SFPUC Commissioners
have heard the testimony from others - todate, the SFPUC have not responded to my letter.

How many times must we state the lies told and the ploys and machinations created to harm and traumatize Joe King, Conrad King, and Adolfo Padilla? It is time the SFPUC commissioners get back to me and state what they have in mind. Every rule and law has been broken - lies have been fabricated - the SF City Attorney and the SFPUC General Manager have chosen to listen - aid and abate Managers the likes of Steve Richie and William Teahan.

The people united will never, ever be defeated.

Francisco Da Costa
Director
Environmental Justice Advocacy

This Message Is From an External Sender
This message came from outside your organization.

Report Suspicious ‌
From: Lourdes Enriquez
To: BAWSCA WMR
Cc: Smegal, Tom; Deborah Grimes; Christiane Barth
Subject: November 20, 2025 BAWSCA Board of Directors Meeting Agenda Date: Thursday, November 13, 2025 3:47:36 PM
Attachments: 25_BAWSCA_Nov20_Agenda_FINAL.pdf
Attached is the agenda for the BAWSCA Board of Directors meeting on Thursday, November 20, 2025 at 6:30pm.

Supporting documentation for agenda items are not included in this email because of its volume. Click here
to download a complete copy of the agenda and attachments for this meeting from our website, or go to: http://bawsca.org/about/board/agendas

If you have questions, please call (650) 349-3000.

Thank you,
Lourdes Enriquez

Lourdes Verzosa-Enriquez
Assistant to the CEO/General Manager
Bay Area Water Supply & Conservation Agency
155 Bovet Road, #650
San Mateo, CA 94402
650-349-3000
www.bawsca.org

BOARD OF DIRECTORS MEETING
Thursday, November 20, 2025
Burlingame Community Center – Sequoia Room
850 Burlingame Ave., Burlingame
6:30 P.M.

CLICK HERE TO VIEW LIVESTREAM

Four (4) members of the Board will participate in this meeting by teleconference at the following locations:
• 43885 S Grimmer Blvd, Fremont, CA 94538
• 225 W 200 S, Salt Lake City, UT 84101
• 255 S West Temple, Salt Lake City, UT 84101
• 69-1033 Nawahine Place, Unit #16c, Waikoloa, HI 96738 When any member(s) of the board participates by teleconference, all votes taken at this meeting will be by roll call vote.

AGENDA
Agenda Item Presenter Page

1. Call to Order/Roll Call/Salute to Flag (Chambers)

2. Comments by the Chair (Chambers)

3. Board Policy Committee Report (Attachment) (Hardy) Pg 3

4. Public Comments (Chambers)
Members of the public may address the Board on any issues not listed on the agenda that are within the purview of the Agency. Comments on matters that are listed on the agenda may be made at the time the Board is considering each item. Each speaker is allowed a maximum of two (2) minutes.

5. SFPUC Report (Ritchie)

6. Consent Calendar (Chambers)
A. Approve Minutes of the September 18, 2025 Meeting (Attachment) B. Receive and File Budget Status Report – As of Sept. 30, 2025 (Attachment) C. Receive and File Annual Audit Report for BAWSCA and Compilation Report for BAWUA for FY 2024-25 (Under Separate Cover)
D. Receive and File Directors’ Reimbursement Report – As of Sept. 30, 2025 (Attachment)
E. Receive and File Employees’ Reimbursement Report – As of Sept. 30, 2025 (Attachment)
F. Receive and File Investment Report – As of Oct. 31, 2025 (Attachment) G. Adoption of Resolution #2025-02 Approving the Extension of the 2021 Amended and Restated Tier 2 Drought Response Implementation Plan (Attachment) H. Annual Review and Consideration of BAWSCA’s Statement of Investment Policy (Attachment)
The Board Policy Committee voted unanimously to recommend approval of the proposed Board action for agenda items #6G and #6H.

Pg 17
Pg 25
Pg 27

Pg 29

Pg 31

Pg 33
Pg 35

Pg 41

7. Reports and Discussions:

A. BAWSCA’s Long-Term Reliable Water Supply Strategy 2050 (Ashoori) Affordability Assessment (Attachment)
Pg 49

8. CEO Reports (Smegal)
A. Bay Delta Plan – State Water Board’s Nov. 5th Workshop (Attachment) B. Results of FY 2022-23 Wholesale Revenue Requirement (Tang) Review (Attachment)
C. CEO’s Letter (Attachment)
D. Board of Directors Policy Calendar (Attachment)
E. Correspondence Packet (Under Separate Cover)

Pg 53
Pg 57

Pg 59
Pg 63

9. Closed Session #1
A. Public Employee Performance Evaluation (Chambers)
Title: Current CEO/General Manager
Closed Session Pursuant to Government Code Section 54957 (Under Separate Cover)

10. Closed Session #2 (Schutte)
A. Conference with Legal Counsel – Existing Litigation pursuant to Paragraph (1) of subdivision (d) of Government Code Section 54956.9 Federal Energy Regulatory Commission Final License Application Proceedings for Don Pedro Hydroelectric Project, P-2299-082, and La Grange Hydroelectric Project, P-14581-002.

B. Conference with Legal Counsel – Existing Litigation pursuant to Paragraph (1) of subdivision (d) of Government Code Section 54956.9 - State Water Board Cases (Third Appellate District Court Case No.

C101232).

11. Report After Closed Session (Schutte)

12. Additional Time for Public Comments (As Time Permits) (Chambers) Members of the public may address the Board on any issues that are within the purview of the Agency

13. Directors’ Discussion: Comments, Questions and Agenda Requests (Chambers)

14. Date, Time and Location of Future Meetings (Chambers) (See attached schedule of meetings)

15. Adjourn to next meeting scheduled for January 15, 2026 at 6:30pm (Chambers)

Pg 65

Accessibility for Individuals with Disabilities
Upon request, BAWSCA will provide for written agenda materials in appropriate alternative formats, or disability-related modification or accommodation, including auxiliary aids or services, to enable individuals with disabilities to participate in and provide comments at/related to public meetings.

Please submit a request, including your name, phone number and/or email address, and a description of the modification, accommodation, auxiliary aid, service or alternative format requested at least two days before the meeting. Requests should be emailed to [email protected] or submitted by phone at 650-349-3000. Requests will be granted whenever possible and resolved in favor of accessibility.

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Robert Hall
To: Commission
Subject: Ask the Historic Preservation Commission to Agendize Crocker Amazon Date: Saturday, November 15, 2025 11:38:41 AM
Attachments: Historic Preservation Comm. - Crocker Amazon renovation 11-12-25.pdf Since this project is on PUC land we hope that you will join us in asking the Historic Preservation Commission to immediately agendize the proposed Crocker Amazon Baseball and Softball Renovation Project and to direct staff to have an historic resource evaluation completed of the site by a cultural landscape specialist meeting the Secretary of the Interior’s Standards. Please see our attached letter outlining the reasons for this request.

While the Recreation and Park Commission will not hear and approve this project on November 20th, they will soon, and there hasn't been a thorough environmental study of the area yet. At a minimum, it is important that the Historic Preservation Commission have the opportunity to evaluate and comment on the proposed project and potential archaeological site. Beyond that, an Environmental Impact Report should be required before this project is approved and this important cultural landscape is destroyed.

There are many reasons why this project is detrimental to the community, to the environment, and to the children it is supposed to serve. We would be glad for an opportunity to talk with you about the project and our concerns. There's more information about this project on our website.

Meanwhile we are available, if you have any questions.

Thank you for your consideration.

Bob Hall
KeepCrockerReal.com
415-609-2699

Crocker Amazon Baseball and So3ball Fields Proposed Renova:on Page 1 of 3

November 12, 2025

Historic Preserva5on Commission
c/o SF Planning Department
49 South Van Ness, Suite 1400
San Francisco, CA 94103

Re: Recrea5on and Park Department: Crocker Amazon Baseball and SoLball Fields Proposed Renova5on (Tenta5ve approval date at RPC on November 20, 2025)

Dear Commission President Matsuda and Commissioners,

We are reques5ng that the Historic Preserva5on Commission agendize the proposed Crocker Amazon Baseball and SoLball Renova5on Project and direct staff to have an historic resource evalua5on completed of the site by a cultural landscape specialist mee5ng the Secretary of the Interior’s Standards, if this work has not been done. We believe that the site is a cultural landscape and request that no work be done at the site un5l an evalua5on is completed and the HPC has provided comments. We also ask that the site be studied for possible items of archaeological significance. We believe that an Environmental Impact Report is warranted given that the majority of the extant trees are proposed to be removed and this ac5on would cons5tute a poten5ally substan5al adverse impact on an historical resource.

Playing fields were first constructed at Crocker Amazon in the 1930’s, on a former SF PUC reservoir of the same name, by the Works Progress Administra5on (WPA) at the request of the San Francisco Recrea5on Commission i. At that 5me, the design of the fields was laid out and trees were planted to define the site’s perimeter and to provide shade and protec5on from wind. When the US Navy used the site for a hospital during World War II, it chose to preserve the spa5al organiza5on of the site by retaining the tree lines bordering the various sec5ons of the site.ii The site was subsequently used for housing and in 1960 returned to playing fields “as a public park space similar to its current design.” iii

For nearly a century, the tree line pabern that borders the site has outlined each playing field and is the primary character-defining feature of the site. The tree pabern has told the story of Crocker Amazon for every person who encounters it. The historic integrity of this cultural landscape is intact and alive. The historic tree line adds to the character and enjoyment of the site - not only for the athletes but also for the neighborhood, which has enjoyed the grass and trees as public park.

Crocker Amazon Baseball and So3ball Fields Proposed Renova:on Page 2 of 3 The proposed project would replace the current fields with ar5ficial grass and add restric5ve fencing and stadium ligh5ng. iv Due to the required grading for ar5ficial turf and other changes to the area, the Crocker Amazon project will have the following nega5ve impacts on the cultural landscape, including:
• Removal of 128 of 173 trees, most of them healthy and suitable for preserva5on: v o These trees form a tree line that was planted around the 5me the fields were created in the 1930’s. (See site photos in Abachment.) o The trees define the outline of the fields and are a major contributor to the shape of the fields.
o The trees also provide major shade, windscreen, and habitat for the area, making this a unique park-like sefng for not only players and spectators but also for the neighbors who enjoy the fields as parkland.
o The Arborist Report shows that a majority of the trees to be removed are s5ll healthy.vi
o New trees would be planted; however, not only would they be very small for many years to come but also they would not be located in the same loca5on as the original trees that outline the shape of the fields. o Loss of the trees would mean loss of the unique, historic character of this site and its conversion to a paved, impersonal, characterless area. (See site photos in Abachment.)
• Possible loss of archaeological significance.
o The site is listed by the Planning Department as Level B Poten5al Archaeological Significance. As far as we know, there have as yet been no studies of the archaeological resources in this area that might be impacted by this project. • Change in the layout of the fields.
o The 1950’s field layout would be changed.

It is important that the Historic Preserva5on Commission have the opportunity to evaluate and comment on the proposed project and poten5al archaeological site. A full Environmental Impact Report would provide the informa5on needed for this decision.

Thank you for your considera5on.

Robert Hall
Keep Crocker Real hbps://keepcrockerreal.com
415-609-2699

cc: Office of the Mayor
Board of Supervisors
Planning Commission
Deputy Director of Current Planning
SF PUC
SF Department of the Environment
Urban Forestry Council
SF Heritage
HALS Northern California Chapter
Living New Deal
SF Preserva5on Consor5um
Friends of the Music Concourse
SFUN San Franciscans for Urban Nature

Crocker Amazon Baseball and So3ball Fields Proposed Renova:on Page 3 of 3

i h#ps://livingnewdeal.org/sites/crocker-amazon-playground-and-recrea<on-center-san-francisco-ca/

ii h#ps://ofshipssurgeons.wordpress.com/2012/07/27/u-s-naval-receiving-hospital-san-francisco-california- december-1944-december-1945/

iii “Crocker Amazon Baseball and SoKball Fields Renova<on,” February 20, 2025. RPD mee<ng presenta<on, Brief site history. h#ps://sfrecpark.org/DocumentCenter/View/25586/Crocker-Amazon-Ballfields---Public- Presenta<on-1-Feb-20-2025

iv Department of Recrea<on and Park project website: h#ps://sfrecpark.org/1820/Crocker-Amazon- Baseball-and-SoKball-Fie

v DraK Arborist Report, December 2021.
vi DraK Arborist Report, December 2021.

Re: Recrea(on and Park Department: Crocker Amazon
Baseball and So:ball Fields Proposed Renova(on
A"achments
In this photo from the 1930’s, the trees of Crocker Amazon Park were already becoming established in a tree line that reflected the field layout. (Source: OpenSFHistory / wnp26.1555, wnp26.1556 , h<p://opens=istory.org/)

This aerial photo from 1965 shows the trees con(nuing to grow larger. (Source: h-ps://sfrecpark.org/DocumentCenter/View/25586/Crocker-Amazon-Ballfields---Public- PresentaJon-1-Feb-20-2025)

The trees were preserved when the park served as a naval hospital and housing from 1944-1960 (Source: h-ps://sfrecpark.org/DocumentCenter/View/25586/Crocker-Amazon-Ballfields---Public- PresentaJon-1-Feb-20-2025)

This drawing shows the trees to be removed by the proposed project:
(Source: Background visual from Google Maps. NotaJons by Keep Crocker Real.)

Just a few of the trees to be removed by this project:
(Source: Keep Crocker Real)

Final project rendering:
(Source: Visual - RecreaJon and Park Department. NotaJon - Keep Crocker Real.)

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From: Alex Lantsberg
To: Commission
Cc: Eric Veium
Subject: Fw: CCA Alliance Letter for Today"s CC Power Board Meeting Date: Wednesday, November 19, 2025 12:37:28 PM
Attachments: Outlook-qedyjo54.png
Outlook-2mhvj4hs.png
CC-Power_Alignment-Request_Letter_111925.pdf
Dear Commissioners,
Please find attached the Workforce and Environmental Justice Alliance's letter to California Community Power regarding its recently issued 2025 Capacity and Generation RFP. It is disappointing to see CCPower fall short of the commitments it has made to ensure the highest workforce and environmental justice standards in its power purchasing activities and I hope that the Commission can exert its influence as CCPower members to reissue the RFP with the appropriate guidelines.

Thank you,
Alex Lantsberg
Director of Research & Advocacy

San Francisco Electrical Construction Industry

55 Fillmore St.

San Francisco, CA 94117
Mobile 415.794.2539
Book time to meet with me
November 19, 2025
Alex Morris
General Manager
California Community Power
901 H St., Suite 120 PMB 157
Sacramento, CA 95814
Subject: Alignment of CC Power’s Procurement Approach with Member CCA Standards Dear Alex,
We want to begin by recognizing the substantial leadership many CC Power member CCAs have shown in adopting strong workforce, community engagement, and environmental standards over the past few years. Because a majority of CCAs have now moved to higher-road policies — including prioritizing project labor agreements (PLAs) with local and targeted hire goals, commitments to workers with barriers to entry, and clearer expectations for community engagement and environmental stewardship — we reviewed the 2025 Clean Generation and Capacity RFP with the expectation that these standards would be meaningfully reflected.

Instead, the RFP contains no references to these member-adopted standards and does not incorporate them into eligibility requirements, qualitative scoring, or proposal expectations.

Labor standards are limited to a pass/fail IRA test, with no scoring encouraging PLAs or other criteria such as local or targeted hire; and community engagement and community benefits are absent. This structure sits in tension with CC Power’s commitment — as previously stated — that the agency will not undermine any member CCA’s policies and will default to the higher of the standards when member requirements differ.

Given this, we respectfully ask that CC Power begin aligning its procurement framework with the higher-road standards adopted by most of its members, and that staff bring forward an approach for embedding these expectations into future solicitations. We request an opportunity to meet with you and your team after this RFP round to discuss a path that upholds the commitments made to member agencies and provides consistent guidance to developers participating in CC Power procurements.

Thank you for your consideration, and please ensure that this letter is included in the public record and in the minutes of today’s board meeting.

Sincerely,
Eric Veium, Tim Frank, Leslie Austin
Co-Directors, CCA Workforce & Environmental Justice Alliance

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From: Francisco Da Costa
To: Francisco Da Costa
Subject: The San Francisco Public Utilities Commission must resolve this case - stop kicking the can down the street.

Date: Sunday, November 23, 2025 9:12:32 AM
Stop kicking the can down the street - and solve the problem - SFPUC workers should not be put in harm's way:
https://kilamanjaro-kilamanjaro.blogspot.com/2025/11/the-sfpu-commission-has-with-intent.html? fbclid=IwY2xjawOQGDVleHRuA2FlbQIxMQBicmlkETFTRk41SHVZUklwckZ2MnFPc3J0YwZhcHBfaWQQMjIyMDM5MTc4ODIwMDg5MgABHpOraNpb4zdzO_Q5Q7sOS51ZyQNcQB6kOoCPaqvScwnGie9yP19T8LMBY1cr_aem_ndQO2yUWsxmKZ3OjuSFF9A Francisco Da Costa
Director
Environmental Justice Adocacy
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From: Dennis
To: Commission
Cc: SFPUC Citizens" Advisory Committee; Customer Service; Southeast Community Center Info; Info; Newsletter; Maika Pinkston; Malik Washington; Waxmann, Laura; FielderStaff; Walton, Shamann (BOS); Ethics Commission, (ETH); demetrius williams; [email protected]; Bilal Mahmood; Ericka Scott; Kenisha Roach; [email protected]
Subject: Introduction – Local Developer & Community Partnership for SEP7 Date: Tuesday, November 25, 2025 1:20:49 PM
SFPUC,
My name is Dennis Williams Jr., a local San Francisco developer and Executive Director of the Fillmore Community Development Corporation. I am reaching out to introduce D.C.

Williams Development as a community-centered development partner interested in supporting the SEP7 projects.

Our work focuses on equitable development, community engagement, local hiring, and LBE/SBE inclusion. We frequently serve as community benefit partners, development advisors, and local engagement leads for public-facing projects.

Attached is a brief introduction packet outlining our capabilities. I would like to schedule time to explore how we can support your team’s community benefit goals and development obligations.

Thank you,
Dennis Williams Jr.

D.C. Williams Development Company
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From: Dennis
To: Commission
Cc: SFPUC Citizens" Advisory Committee; Customer Service; Southeast Community Center Info; Info; Newsletter; [email protected]; Malik Washington; Bilal Mahmood; Waxmann, Laura; Walton, Shamann (BOS); Ethics Commission, (ETH); Maika Pinkston; Kenisha Roach; FielderStaff; [email protected]; demetrius williams; Ericka Scott; [email protected]; Francisco Da Costa Subject: Local inclusion opportunities
Date: Tuesday, November 25, 2025 1:44:45 PM
D.C. Williams Development – Developer
Introduction Packet

1. Cover Introduction Statement
D.C. WILLIAMS DEVELOPMENT COMPANY
Local San Francisco Developer | Community Economic Development Leader | Fillmore CDC D.C. Williams Development is a San Francisco–based real estate development firm specializing in community-centered development, equitable revitalization, and local inclusion strategies. As a local developer deeply rooted in San Francisco’s historic Black communities, we bring expertise in community engagement, development planning, and local workforce integration.

We work closely with public agencies, community groups, and prime contractors to ensure major capital projects deliver real, measurable benefits to San Francisco residents — including local hiring, LBE inclusion, equitable contracting, and long-term community investment.

Our team is available for roles in:

Community benefits partnerships
Local hire & workforce coordination
Community stakeholder engagement
Predevelopment advising
Joint venture development (public + P3 projects)
Compliance support for SFPUC, and city agencies

2. Company Profile (Developer Focus)
D.C. Williams Development Company
Local Real Estate Developer | Community Development Partner | Economic Inclusion Strategist
Core Expertise
Urban infill & mixed-use development
Affordable housing partnerships
Community benefit strategy development
Economic inclusion & procurement strategy
Developer-level project management
Public-private development (P3 & Joint Venture)
Neighborhood revitalization with equity focus
Active Roles in the Community
Executive Director, Fillmore Community Development Corporation Advocate for equitable development in San Francisco
Partner to community organizations, workforce pipelines, and trades Value Proposition for Major Projects
D.C. Williams Development offers prime contractors and public agencies a uniquely qualified partner who can:

Connect projects with local workforce, trades, and LBEs Support outreach, compliance, reporting, and community accountability Strengthen developer/contractor presence with local stakeholders Build community trust and mitigate political risk
Provide development advisory rooted in lived experience and technical capacity

3. Community Impact & Partnership
Capabilities
A. Community Engagement & Public Communication
Organize, host, and facilitate community meetings
Build bridges with neighborhood leaders, nonprofits, and residents Document and report on community impact metrics
B. Local Hire + Workforce Integration
Pipeline access to San Francisco trades
Partnerships with community workforce organizations
Strategic planning around targeted hiring
C. LBE/SBE Inclusion Strategy
Assist primes in meeting or exceeding LBE goals
Introduce vetted, qualified subcontractors and consultants Support matchmaking and partnership building
D. Accountability, Compliance, and Reporting
Support compliance for SFPUC, and city-mandated programs Provide documentation, community benefit tracking, and reporting frameworks

4. Current Capacity & Focus Areas
Development Areas of Focus
Affordable and mixed-income housing
Community-serving commercial projects
Cultural preservation and equity-centered development
Neighborhood revitalization aligned with historic Black communities Public facility partnerships (childcare, community centers, cultural hubs) Professional Strengths
Real estate development planning
Owner’s rep + development advisory
Community relations and stakeholder alignment
Policy advocacy and negotiating development outcomes

5. Project Interests
For SEP7, and similar projects, we are positioned to participate as:

Community Benefits Partner
Local Developer Advisor
Joint Venture Community Development Partner
Equity + inclusion implementation partner
Predevelopment advisor for future public parcels
Our goal is to ensure public investments benefit the people of San Francisco — especially historically excluded communities.

D.C. Williams Development Company
Dennis Williams Jr., Principal
Executive Director, Fillmore Community Development Corporation San Francisco, CA
(415) 741-9903
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From: aeboken
To: Commission, Fire (FIR); Crispen, Dean (FIR); Commission; Robinson, Stephen D; [email protected]; Short, Carla (DPW); Deborah Murphy; Charles Head Subject: Coalition for San Francisco Neighborhoods Resolution re Transferring AWSS from SFPUC Back to SFFD Date: Wednesday, November 26, 2025 11:38:38 AM
Attachments: AWSS Resolution.pdf
TO: SF Fire Commission
cc: Chief Crispen
SFPUC Commission
cc: Stephen Robinson
SF Public Works Commission
cc: Carla Short
FR: Eileen Boken,
State and Federal Legislative Liaison
Coalition for San Francisco Neighborhoods
RE: Coalition for San Francisco Neighborhoods Resolution re Transferring Auxiliary Water Supply System (AWSS) from SFPUC Back to SFFD
Please find attached a resolution unanimously passed by the Coalition for San Francisco Neighborhoods at its November 2025 General Assembly meeting.

Based on the rationale stated in the whereas clauses in the resolution, the Coalition for San Francisco Neighborhoods is advocating for the transfer of AWSS from the SFPUC back to the SFFD.

This transfer would include jurisdiction, assets and Earthquake Safety and Emergency Response (ESER) bond funds from the 2010, 2014 and 2020 bonds which are either unencumbered or encumbered.

It would also include any funds from future ESER bonds. ###
Sent from my Verizon, Samsung Galaxy smartphone

November 18, 2025

Mayor Daniel Lurie
Paul Yep, Chief for Public Safety
Han Zou, Communication Director
Dean Crispen, Chief of Fire Deptartment
Garreth Miller, Assistant Deputy Chief, ESER Project Manager Carla Short, Director of Deptartment of Public Works
Scott Anderson, Deputy Director for Project Delivery
Stephen Robinson, Assistant General Manager for Infrastructure Carmen Chu, City Administrator
Brian Strong, Director for Office of Resilience and Capital Planning

CSFN Resolution Advocating for the Transfer of the Auxiliary Water Supply System

WHEREAS, As a result of the 1906 earthquake, San Francisco voters approved a General Obligation Bond to build a firefighting system of water pipes, hydrants and pumps which are independent of the City's drinking water system.

WHEREAS, This system was completed in 1913 and was designated as the Auxiliary Water Supply System (AWSS).

WHEREAS, In 1913 AWSS coverage was primarily in the northeast quadrant of the City.

WHEREAS, Even though AWSS has been expanded since 1913, large areas in both the Westside and Southeast currently have no AWSS protection.

WHEREAS, Since 1913 AWSS and its assets have been under the jurisdiction of the SF Fire Department (SFFD) with design and engineering under the auspices of the SF Department of Public Works (SFDPW).

WHEREAS, In 2010, despite an ESER Bond being on the ballot, then Mayor Gavin Newsom balanced the City's Great Recession budget by transferring AWSS jurisdiction and assets from the SFFD to the SFPUC.

WHEREAS, Since 2010 the SFPUC has implemented a number of AWSS policies which have had significantly negative impacts on the system.

WHEREAS, Instead of expanding AWSS, the SFPUC installed a system of cisterns on the Westside.

WHEREAS, Even though SFFD has only 44 fire apparatus, a single cistern requires two fire apparatus to extinguish fires; one to pump water out of the cistern and one to extinguish the fires.

WHEREAS, Once the fires are extinguished, a cistern does not automatically refill but must be refilled manually.

WHEREAS, The SFPUC then attempted to implement the Flexible Water Supply System (FWSS) which uses 350 lb hoses but was forced to abandon this approach as infeasible.

WHEREAS, The SFPUC is now attempting to implement a potable (drinking) water AWSS system which theoretically has the co-benefits of using a single water pipe for both drinking water and emergency firefighting.

WHEREAS, Although the SFPUC has stated that this concept comes from Japan, no fire departments in Japan seem to use it.

WHEREAS, Despite its naming convention, potable water AWSS does not primarily use drinking water but primarily uses "raw" water from Lake Merced.

WHEREAS, Once raw water enters drinking water pipes, the SF Department of Public Health would be required to issue a "boil water" alert.

WHEREAS, Once the catastrophic fires have been completely extinguished, water pipes which have been contaminated with raw water would need to be flushed out over a period of weeks even months.

THEREFORE, be it resolved, Based on the SFPUC's numerous policy missteps regarding AWSS, CSFN insists that the current mayor initiate a process to transfer the AWSS jurisdiction and assets from the SFPUC back to the SFFD including current unencumbered and encumbered AWSS funds in the Earthquake Safety and Emergency Response (ESER) Bond program, as well as, any future AWSS funds from the proposed June 2026 ESER Bond.

Deborah Murphy
President CSFN
[email protected]
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From: Dave Warner
To: Lennear, Tiffany
Cc: Herrera, Dennis J; Ritchie, Steve; Hom, Nancy; Busch, Laura; Corvinova, Erin E Subject: Affordability is a hot topic at BAWSACA
Date: Monday, December 1, 2025 3:37:19 PM
Attachments: Affordability is a hot BAWSCA topic 2025-12-01.pdf Hi Tiffany,
Hope you had a great Thanksgiving! Is the attached letter in time to be added to the correspondence materials for the next commission meeting? I've copied here all the SFPUC people on my cc list.

Best regards,
Dave

December 1, 2025

December 1, 2025
Re: A/g431ordability is a hot topic at BAWSCA
Dear Commissioners,
At the last two BAWSCA Board meetings, aUgR)Lordability received a lot of attention. At their October 8
th Policy Committee meeting, most of the time
was spent on aUgR)Lordability. At the November 20 th board meeting, the most discussed topic was aUgR)Lordability.

The vast majority, if not all, of the Directors were concerned about aUgR)Lordability. It seemed like there was a perfect storm of challenges:
- SFPUC water rates and risks of increases above projections from factors such as capital spending or demand not growing as expected. - Local agencies need to maintain/update their infrastructure. - Proposition 218 challenges driving agencies to reduce/eliminate multi- tier rate structures which place pressure on lower income households.

Please consider:
1) Asking for a wholesale rate sensitivity analysis using lower BAWSCA long-term demand estimates, along with a retail aUgR)Lordability sensitivity analysis.
1 2) Please ask for an analysis of how the SFPUC might reduce its Regional Water System spending projections by 10% per year against the the FY 2026 10 year financial projections. This is a significant ask as about 50% of costs are tied to debt service. Even if such an analysis is not implemented, it would be instructive for understanding the diUgR)Liculty. 2 Doing such an exercise sooner than later benefits all.

1 The finance team points out that retail aUgR)Lordability is primarily driven by the number of projected new accounts as otherwise declines in demand oUgR)Lset rate increases such that average bills would remain the same.
2 Alternatively, form a subcommittee of commissioners to work with the finance team to examine various spending reduction scenarios and how the scenarios would impact rates and aUgR)Lordability under multiple downside demand scenarios.

December 1, 2025

Kind regards,

Dave Warner

cc: Dennis Herrera, SFPUC General Manager
Steven Ritchie, SFPUC Assistant General Ma nager, Water Enterprise Nancy Hom, SFPUC Chief Financial Officer
Laura Busch, SFPUC Deputy Chief Financial Officer
Erin Corvinova, SFPUC Financial Planning D irector
Tom Smegal, BAWSCA CEO

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This message came from outside your organization. Report Suspicious From: Peter Drekmeier
To: Commission; Lennear, Tiffany
Subject: Letter to Commissioners
Date: Tuesday, December 2, 2025 2:27:16 PM
Attachments: YRA Letter to SFPUC - TVA Scientific Basis Report.pdf PastedGraphic-1.png
Hi Tiffany,
Could you please share the attached letter with the Commissioners? Thank you very much.
-Peter
Please note my new email address.
-----------------------
Peter Drekmeier
Policy Director
Yosemite Rivers Alliance
(Formerly Tuolumne River Trust)
[email protected]

December 2, 2025

President Josh Arce and Commissioners
SFPUC
[email protected]

Re: Tuolumne River Voluntary Agreement draft Scientific Basis Report.

Dear President Arce and Commissioners:

It would be prudent for the SFPUC to host a workshop on the Tuolumne River Voluntary Agreement (TVA) and the recently- released draft Scientific Basis Report (SBR). It’s been years since the TVA has come to the Commission, and much has changed in that time. None of the current Commissioners has benefited from previous discussions on the differences between the Bay Delta Plan and the TVA.

Yosemite Rivers Alliance would be very interested in providing a presentation.

Following are some citations from the Scientific Basis Report to whet your appetites.

Sufficient Flows Are Critical for Fish

“Fish habitat quantity and quality on the Tuolumne River is primarily controlled by flows.” – SBR, p. 2-15.

“This is consistent with increases in fry, smolt, and total juvenile survival indices between Tuolumne River rotary screw trap monitoring at Waterford (RM 29.8) and Grayson (RM 5.2) when flows were elevated from flood control releases (Table 2-3). For example, total juvenile survival indices were 24.9% and 94.8% for 2011 and 2017, respectively, whereas survival was below 8% in the other years.” – SBR, p. 2-16.

Note: Juvenile fish were much more abundant and survival was much higher in the wet years (2011 and 2017) than in the other years.

“The TVA is expected to result in new flow contributions (change relative to Existing Conditions) downstream of La

2 Grange Dam from January through June that range from 2 to 12 thousand-acre feet (TAF) per year on average…” – SBR, p. ES-6.

Note: The average yield of the Tuolumne River is 1,850 TAF.

“From 1970 to 2024, 17 out of the 55 years would have included sequential dry year off-ramps which is a frequency of 1 out of every 3 years.” – SBR, p. 5-65.

Note: Off-ramps would decrease flows substantially in the years when fish need it most.

The TVA Does Not Prioritize Limiting Factors

"These findings suggest that spawning habitat and instream rearing habitat are not as limiting to recruitment as temperature, flow, and floodplain habitat during the rearing period in the Tuolumne River (Table 2-6).” – SBR, p. 2-29.

Water Temperature

“Providing suitable water temperatures is critical to the health of the lower Tuolumne River aquatic ecosystem. Water temperature influences every freshwater life stage of anadromous salmonids…” – SBR, p. 2-26.

“Water temperature is likely the most important abiotic factor (besides water itself), in the environment for fish and the ecosystem for which they depend, because without suitable water temperatures habitats become unusable.” – SBR, p. 5-1.

“…the TVA temperatures would exceed the Existing Conditions scenario from mid-April through mid-May when the off-ramps are being implemented.” – SBR, p. 5-69.

Rearing Habitat

“Floodplain habitat provides substantial benefits to juvenile Chinook salmon by supporting faster growth and higher survival through improved access to drift invertebrate prey, greater feeding success, and refuge from predators (Sommer et al. 2001; Jeffres 2008; see Section

7.2.2.2, Growth Benefits in Floodplains, of Chapter 7).” – SBR, p. 2-29.

“Existing habitat availability on the lower Tuolumne River is far less than what is estimated to be required to recover listed salmonid species populations. For example, it is estimated that rearing habitat in the Tuolumne River can only support the offspring from no more than 434 fall-run Chinook salmon adults during managed flow releases (Mesick 2009).” – SBR, p. 2-3.

Predation

“In general, reduced spring flows, elevated water temperatures, and the presence of low- velocity habitats…favor fish communities dominated by non-native, warmwater species, such as 3 largemouth bass and other potential predators on native salmonids (EA 1992; McBain & Trush 2000; Brown and Ford 2002).” – SBR, p. 2-5.

“Another predation study performed on the Tuolumne River at high flows found no salmonid predation occurred (Stillwater Sciences and McBain & Trush 2006).” – SBR, p. 2-5.

“Predator control is not likely to be effective on a broad scale without considering the habitat conditions that make non-native predators successful.” – SBR, p. 6-6.

Bay-Delta Ecosystem Improvements

“These volumes, when provided, will not be subject to flow protection below La Grange Diversion Dam. It’s expected that these flows will be released when the State Water Project and the Central Valley Project (Projects) would be able to increase exports, which means these flows would not result in Delta outflow.” – SBR, p. 3-3.

If you would like to view my presentation to the State Water Board at the recent TVA workshop, it’s available at 5:09:00 at https://www.youtube.com/watch?v=Pbg0wr4k3Dc

Thank you for the opportunity to submit my request for a workshop.

Sincerely,

Peter Drekmeier
Policy Director
[email protected]