advertising[.]" (Business and Professions Code Section 17200.). As recently summarized by the California Supreme Court:
The statute’s purpose is to protect both consumers and competitors by promoting fair competition in commercial markets for goods and services. In service of that purpose, the Legislature framed the UCL’s substantive provisions in broad, sweeping language to reach anything that can properly be called a business practice and that at the same time is forbidden by law. By proscribing any unlawful business practice, section 17200 borrows violations of other laws and treats them as unlawful practices that the unfair competition law makes independently actionable. [T]he Legislature…intended by this sweeping language to permit tribunals to enjoin on-going wrongful business conduct in whatever context such activity might occur. To that end, the Legislature has created a scheme of overlapping enforcement authority. […] While the UCL provides for both public and private enforcement, authorized public prosecutors have an additional tool to enforce the state's consumer protection laws:
civil penalties. (Abbott Laboratories v. Superior Court (2020) 9 Cal. 5th 642, 651-52 [internal citations and quotations omitted.])
Remedies under the UCL include injunctive relief, restitution, and civil penalties. It is important to note that even though a district attorney or the Attorney General can take an action to enforce these chemical prohibitions in the "orphan codes" using the UCL, before a case is filed, a member of the public must purchase and test products at a certified laboratory for the prohibited chemical, which is expensive. Then, the Attorney General or district attorney must have the resources and ability to prioritize action on these complaints before other responsibilities.
To date, the Committee is unaware of any comprehensive report or investigation by any entity on compliance with the chemical prohibitions in the "orphan code," nor is it aware of any entity that is sampling, testing, or tracking compliance with the "orphan codes." Additionally, to date, the Committee is not aware of any enforcement actions taken by the Attorney General or a district attorney under the UCL, or any other law, to enforce any of the chemical prohibition laws under the "orphan codes."
This bill: While the provisions of this bill are placed under the "orphan" section of the Health and Safety Code, the author has added provisions that provide government attorneys with civil penalty options to bring against violators of the law. Specifically, this bill provides that, upon an action brought by the Attorney General, a city attorney, a county counsel, or a district attorney, a person or entity that violates the PFAS restrictions for covered surfaces as delineated in this bill shall be liable for a civil penalty, capped at $5,000 for a first violation and $10,000 for each subsequent violation. The bill additionally provides that these penalty provisions do not impair or impede any other rights, causes of action, claims, or defenses available under any other law.
AB 1423 also provides that the remedies delineated in the bill are cumulative with any other remedies available under any other law. These penalty provisions are in addition to the authority for government attorneys to enforce under the UCL, and are consistent with existing statutory penalties relating to PFAS in firefighting foam.
In addition to the penalty provisions currently included in the bill, the author has indicated that she is willing to continue to work with the Committee and stakeholders on a comprehensive enforcement program for dangerous chemicals in products.
AB 1423
Acceptable levels of exposure to PFAS: This bill prohibits PFAS in a covered surface at or above one ppm, as measured in total organic fluorine. There are two other bills pending before the Committee with differing PFAS thresholds in different product categories, and 5 statutes with differing PFAS thresholds for other products (see the "Existing Law" section of this analysis.) As with enforcement, setting thresholds on chemicals in products would benefit from a public entity with oversight responsibility. In that case, a team of scientists with related public health backgrounds could set the appropriately protective thresholds and be able to update the thresholds through regulation consistent with emerging science. Without that resource, the Legislature is tasked with setting the appropriately protective standard in statute, and presumably updating those statutory thresholds by legislation when needed.
For the thresholds set in this bill, the author’s office argues, "Artificial turf requires a more stringent limit [than other uses of PFAS] due to a few factors and it should not be compared to other products like clothing, food packaging, and children’s products. The most important distinctions are weathering and mechanical stress. In terms of weathering, artificial turf spends its entire life outside in the sun and rain. Many other products are not intended by the manufacturer to be used outside, full time, for 8-12 years in all weather. This weathering increases the risk posed by this product as it sheds PFAS laden plastic dust. ...For mechanical stress, artificial turf is intended to be played on with shoes, cleats, and other sports equipment with significant force. This mechanical grinding creates small particles that children inhale, ingest, and come into dermal contact with. A secondary concern is similar to other products in that it also leaches PFAS from its plastic "encapsulation"; however, the sheer size and scope of this product sitting outside statewide means that it should be treated differently with acres and acres of fields capable of leeching PFAS into stormwater and groundwater."
Regrettable substitutions: While each of the laws listed in the "orphan code" prohibit a chemical that has been suspected of or found to be toxic or hazardous the laws do not prevent a manufacturer from replacing the prohibited chemical with another hazardous chemical, or a chemical even more hazardous than the one prohibited. In addition, several of the laws dealing with chemicals in the "orphan code" require manufacturers to use the least toxic alternative when replacing the chemical in question. Without a state entity overseeing these substitutions, it is difficult or impossible to know whether manufacturers are replacing prohibited chemicals with substances that are safer or more hazardous.
This bill: This bill requires a manufacturer of a covered surface to use the least toxic alternative when replacing regulated PFAS in a covered surface.
Moving forward: This bill, along with the other PFAS bills pending in front of the Committee, takes a step forward on statutory chemical prohibitions by adding civil penalties for violations of the restrictions in the bill. However, there remains no entity proving guidance or ensuring compliance with the prohibitions. Moving forward, the authors of these bills, along with stakeholders, the Committee, and the Administration, should continue to discuss effective oversight of these new and existing chemical prohibition laws.
Related legislation:
1. AB 246 (Papan). Prohibits, beginning January 1, 2025, a person from manufacturing, distributing, selling, or offering for sale a menstrual product that contains intentionally-added PFAS, and beginning January 1, 2027, a menstrual product that contains PFAS at or above AB 1423
10 PPM. This bill is pending before the Assembly Environmental Safety and Toxic Materials Committee.
2. AB 727 (Weber). Prohibits, beginning January 1, 2025, a person from manufacturing, selling, delivering, distributing, holding, or offering for sale, a cleaning product that contains intentionally-added PFAS or PFAS at or above 50 PPM, and on January 1, 2027, a cleaning product that contains PFAS at or above 25 PPM. This bill is pending before the Assembly Environmental Safety and Toxic Materials Committee.
3. AB 1817 (Ting, Chapter 762, Statutes of 2022). Prohibits, beginning January 1, 2024, a person from distributing, selling, or offering for sale in the state a textile article, as defined, that contains regulated PFAS, and requires a manufacturer to use the least toxic alternative when removing regulated PFAS in textile articles to comply with the provisions of the bill.
4. AB 2771 (Friedman, Chapter 804, Statutes of 2022). Prohibits, commencing January 1, 2025, a person or entity from manufacturing, selling, delivering, holding, or offering for sale in commerce any cosmetic product that contains intentionally added PFAS.
5. AB 1200 (Ting, Chapter 503, Statutes of 2021). Prohibits, commencing January 1, 2023, the sale of food packaging that contains PFAS; requires, commencing January 1, 2024, cookware manufacturers to label their product if it contains an intentionally added chemical on specified lists; and prohibits, commencing January 1, 2023, for the internet and January 1, 2024, for the cookware package, a cookware manufacturer from making a claim that cookware is free of a chemical, unless no chemical from that chemical class is intentionally added to the cookware.
6. AB 652 (Freidman, Chapter 500, Statutes of 2021). Prohibits, on or after July 1, 2023, a person from selling or distributing in commerce any new juvenile products that contain PFAS.
7. SB 1044 (Allen, Chapter 308, Statutes of 2020). Prohibits the manufacture, sale, distribution, and use of firefighting foam containing PFAS chemicals by January 1, 2022, with some exceptions, and requires notification of the presence of PFAS in the protective equipment of firefighters.
8. SB 1056 (Portantino, 2020). Would have required the State Water Board to establish an analytical laboratory method that can be used as a tool to assess the extent of PFAS contamination in drinking water, surface water, groundwater, and wastewater. This bill was held in the Senate Environmental Quality Committee.
9. AB 756 (C. Garcia, Chapter 162, Statutes of 2019). Authorizes the State Water Board to order one or more public water systems to monitor for PFAS and requires municipalities to notify consumers for PFAS detected above notification levels.
10. AB 841 (Ting, Chapter 372, Statutes of 2019). As heard by the Assembly, would have required OEHHA to assess PFAS substances, especially as they might be found in drinking water, to determine which might pose a potential risk to human health. The contents of this bill were deleted in the Senate and amended with unrelated content.
AB 1423
11. AB 958 (Ting, 2018). Would have required a manufacturer of food packaging or cookware sold in the state to visibly disclose on an exterior location of the food packaging or cookware packaging a specified statement relating to the presence of PFAS in the product. This bill was held on the Senate Floor.
12. SB 1313 (Corbett, 2008). Would have prohibited the manufacture, sale, or distribution of any food contact substance, as defined, which contains perfluorinated compounds, as defined, in any concentration exceeding 10 parts per billion. This bill was vetoed by Governor Arnold Schwarzenegger whose veto message said, "I have signed AB 1879 (Feuer) and SB 509 (Simitian) which mark the beginning of California's historic Green Chemistry Initiative. It is within this process that chemicals like PFCs should be addressed." REGISTERED SUPPORT / OPPOSITION:
Support
A Voice for Choice Advocacy
Active San Gabriel Valley
American College of Obstetricians and Gynecologists District IX Ban Single Use Plastic (SUP)
California Product Stewardship Council
California Professional Firefighters
Clean Water Action
Climate Reality Project, Los Angeles Chapter
Climate Reality Project, San Fernando Valley
Elders Climate Action, NorCal and SoCal Chapters
Environmental Working Group
Friends Committee on Legislation of California
Glendale Environmental Coalition
National Stewardship Action Council
Natural Resources Defense Council (NRDC)
Safe Healthy Playing Fields, Inc.
Sierra Club California
Surfrider Foundation
Urban Ecology Project
Opposition
None on file.
Analysis Prepared by: Shannon McKinney / E.S. & T.M. /
Date Submitted [DATE]
Submitting Department SFPUC
Contact Name Rebecca Peacock
Contact Email and Phone Number [email protected] / 415-757-8365 SLC Meeting Presenter Rebecca Peacock
Reviewed and approved by Department Head? YES NO Reviewed and approved by Commission? YES NO X N/A AB 1423
Asm. Schiavo, Asm. District #40, Democrat
Product safety: perfluoroalkyl and polyfluoroalkyl substances: artificial turf or synthetic surfaces Recommended Position
SPONSOR X SUPPORT SUPPORT if amended OPPOSE OTHER & Describe Summary
This bill would require manufacturers and installers of artificial turf proposing to design, sell, or install a field with a covered surface to any party to notify the party at the earliest possible date that the covered surface contains regulated perfluoroalkyl and polyfluoroalkyl substances (PFAS). Beginning in 2024, it would restrict public entities ! ability to purchase and install artificial turf and other surface coverings. This includes cities, counties, charter cities, public and private K-12 schools, and public and private higher education institutions. By 2025, the bill would prohibit the manufacture, distribution, or sale of any covered surface that contains regulated PFAS.
The SFPUC recommends a support position for AB 1423.
Background/Analysis
PFAS (per and polyfluoroalkyl substances) are a group of chemicals that do not break down and have negative health impacts.
The U.S. Environmental Protection Agency (EPA) has proposed exceptionally low health advisory levels as well as maximum contaminant levels for certain PFAS in drinking water. Additional regulatory action is expected and PFAS monitoring will eventually be included in National Pollutant Discharge Elimination System (NPDES) permits. Proposed Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designation for PFAS could potentially make public utilities vulnerable to superfund liability claims despite the fact the public utilities are merely passive receivers of these compounds. Current wastewater treatment processes do not destroy PFAS and the only realistic way to reduce PFAS in SFPUC effluent and biosolids is to reduce the sources of PFAS entering the collection system.
Legislation which primarily aims to protect Californians from exposure to PFAS also reduces the amount of PFAS arriving at SFPUC wastewater treatment plants. In previous legislative sessions PFAS has been banned in firefighting foam, food packaging, juvenile products, cosmetics, and textiles.
Challenge
There has been a significant increase in regulatory action around PFAS at both the State and Federal level as the scientific community has established that these compounds are a significant threat to the environment and human health. The only realistic way to prevent human exposure and environmental release of these compounds is to limit their use. The only strategy available to the SFPUC to reduce PFAS entering its wastewater treatment plants is to reduce the amount of PFAS being used in its service area through source reduction. AB 1423 would limit environmental release of PFAS by prohibiting its use in artificial turf beginning in 2025. The SFPUC operates a combined sewer system and any runoff from artificial turf in San Francisco during rain events will eventually reach an SFPUC treatment plant.
Solution/Recommended Proposal
The SFPUC recommends a support position as it will reduce the amount of PFAS being transported to wastewater treatment plants and protect the health and safety of Californians who regularly use artificial turf for recreation and athletic events.
Departments Impacted & Why
As the EPA and State Water Board introduce more regulations around PFAS, if nothing is done to reduce PFAS entering wastewater treatment plants, the SFPUC Wastewater Enterprise could eventually find it difficult to meet PFAS regulatory requirements.
We have consulted the following departments regarding this position:
Environment Department
SFUSD
Rec & Park
Fiscal Impact
An inability to meet future PFAS regulation could result in additional costs of tens of millions of dollars annually if changes in effluent and biosolids management were required. This could entail the construction of as-of-yet undeveloped treatment technologies or other costly changes in management practices.
Support / Opposition
Support (as of April 13, 2023)
A Voice for Choice Advocacy
Active San Gabriel Valley
American College of Obstetricians and Gynecologists District IX Ban Single Use Plastic (SUP)
California Product Stewardship Council
California Professional Firefighters
Clean Water Action
Climate Reality Project, Los Angeles Chapter
Climate Reality Project, San Fernando Valley
Elders Climate Action, NorCal, and SoCal Chapters
Environmental Working Group
Friends Committee on Legislation of California
Glendale Environmental Coalition
National Stewardship Action Council
Natural Resources Defense Council (NRDC)
Safe Healthy Playing Fields, Inc.
Sierra Club California
Surfrider Foundation
Urban Ecology Project
Opposition (As of April 13, 2023)
None on file.
1 From: Flynn, Ronald P
Sent: Friday, June 12, 2026 8:28 AM
To: Susan Mullaney
Cc: SF Project Review; Herrera, Dennis J; Lennear, Tiffany; Mauer, Dan (REC); Madland, Sarah (REC)
Subject: RE: Urgency regarding PFAS pollution
Ms. Mullaney,
You are correct that SFPUC owns title to the land at Crocker Amazon. But the SFPUC has not dictated control over the use of the property for decades.
Allow me to explain. This property is not part of our water system, and it does not drain into our water sources (either surface or groundwater). Instead, the property was purchased in the early 1900s with a plan to create a new in-city above-ground reservoir for water storage. Over 90 years ago, in 1933 (Resolution No. 254), SFPUC granted RPD the permission to use the property for recreation purposes. Almost 70 years ago (in January 1957, Resolution No. 16,919) the SFPUC abandoned the idea of building a reservoir at Crocker Amazon and declared the property surplus. In that same resolution SFPUC reaffirmed its grant to RPD to use the land for recreation, subject to certain limitations. Finally, over 45 years ago (May 12, 1981, Resolution No. 79-0361), SFPUC Commission resolved that “This Commission has no reason to be involved in determining specific uses of property previously granted to the Recreation and Park Commission in terms of their occupancy,” and rescinded all previous conditions related to RPD’s use of the property.
RPD has relied upon that grant from the SFPUC Commission over those decades and has dedicated resources and planning to the Recreation at Crocker Amazon. It is in that context that SFPUC is not part of the decision-making process at Crocker Amazon, and instead directs inquiries related to the recreational use plans at Crocker Amazon to RPD.
Copied here are RPD persons who you can engage with on this issue.
Ronald P Flynn (he/him)
Deputy General Manager and Chief Operating Officer
From: Susan Mullaney <[email protected]>
Sent: Thursday, June 11, 2026 4:38 PM
To: Commission <[email protected]>
Cc: SF Project Review <[email protected]>; Herrera, Dennis J <[email protected]>; Flynn, Ronald P <[email protected]>
Subject: Urgency regarding PFAS pollution
2 Dear Commissioners, T he Recreati on and Parks Department (RPD) is knowi ngly polluting the rainwat er runoff and likely the soil surrounding Sa n Fra ncisc o's artifici al turf athletic fi elds with PFAS chemi cals . They've know n for years that ZjQcmQR YFpfptBa nnerStart
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious
ZjQcmQR YFpfptBa nner End
Dear Commissioners,
The Recreation and Parks Department (RPD) is knowingly polluting the rainwater runoff and likely the soil surrounding San Francisco's artificial turf athletic fields with PFAS chemicals. They've known for years that their artificial turf contains PFAS. This has been confirmed by Dan Mauer (Project Manager, Capital Improvement Division) and General Manager Sarah Madland in internal communications.
San Francisco's drinking water contains a percentage of groundwater from the Westside Basin, an aquifer on the west side of the city. Since rainwater leaches toxins from the fields, the Public Utilities Commission (PUC) requires that artificial turf installations over the Westside Basin capture rainwater and route it into the sewer. With San Francisco's combined stormwater/wastewater system, this ensures the toxic runoff reaches the treatment plants.
The PUC tested rainwater runoff from two artificial turf athletic fields in three consecutive winters in 2009-2012. They found elevated levels of heavy metals and Bis-(2-ethylhexyl)-phthalate (DEHP). The official Prop 65 website says DEHP can cause birth defects, may harm the male reproductive system, and exposure during pregnancy may affect the development of the child. Both the PUC and RPD knew about the toxicity of the rainwater, and could obviously extrapolate that children using the field were being exposed. RPD should have shut down the fields and remediated the contamination. They did not. At the least, RPD should have posted Prop 65 warning signs at the field entrances, but did not. We have more details on our website: http://keepcrockerreal.com/files
In 2023, Rebecca Peacock of the PUC notified RPD that the PUC would like to support AB 1423 (Schiavo), state legislation that would ban artificial turf containing PFAS. She provided an informational document that PUC intended to present to the State Legislation Committee. The document is attached. These are important points:
PFAS (per and polyfluoroalkyl substances) are a group of chemicals that do not break down and have negative health impacts; the scientific community has established that these compounds are a significant threat to the environment and human health.
There has been a significant increase in regulatory action around PFAS at both the State and Federal level; additional regulatory action is expected.
PFAS has been banned in firefighting foam, food packaging, juvenile products, cosmetics, and textiles.
Current wastewater treatment processes do not destroy PFAS.
The only strategy available to the SFPUC to reduce PFAS entering its wastewater treatment plants is to reduce the amount of PFAS being used in its service area through source reduction.
Runoff from artificial turf in San Francisco during rain events will eventually reach an SFPUC treatment plant.
The SFPUC Wastewater Enterprise could eventually find it difficult to meet PFAS regulatory requirements.
PFAS monitoring will eventually be included in National Pollutant Discharge Elimination System (NPDES) permits.
3 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designation for PFAS could potentially make public utilities vulnerable to superfund liability claims despite the fact the public utilities are merely passive receivers of these compounds.
An inability to meet future PFAS regulation could result in additional costs of tens of millions of dollars annually.
In its 2022 Contaminants of Emerging Concern report, regarding PFAS chemicals, the PUC stated:
"PFAS do not occur and are not expected to occur in SFPUC source waters or drinking water, based on available monitoring data and the fact that SFPUC watersheds and source waters are not impacted by significant wastewater and industrial discharges or urban runoff. Future recharge of reclaimed wastewater will need to be monitored to ensure that groundwater is not affected."
This is false. PUC distributes drinking water containing well water from the Westside Basin aquifer.
That aquifer does receive urban runoff, including rainwater that is not captured by artificial turf field drainage systems. RPD installs artificial turf in playgrounds and dog plays areas, none of which route drainage to the sewer, instead contaminating soil and reaching groundwater.
The report continues, "Given limited water supplies in California, reclaimed water use will continue to increase. Currently, a reclaimed water facility is under construction at SFPUC's Oceanside Water Pollution Control Plant (OSP), which will be used for irrigation purposes and possibly to recharge groundwater in the future like Orange County in the Los Angeles area. Since there is a risk that reclaimed water contains PFAS, it is prudent to begin planning for monitoring of PFAS in groundwater."
The 2022 report includes test results for 25 of the approximately 14,000 PFAS molecules. A separate 2025-2026 test summary shows PUC now tests for only 29 PFAS molecules. There are other test methods available that provide a better gauge of PFAS presence. Alternate tests should be performed that quantify total organic fluorine since many of the PFAS molecules have additive effects -- small amounts of several chemicals do the harm of that sum of a single chemical.
The PUC must prevent the Recreation and Parks Department from continuing to install artificial turf in San Francisco, must compel them to remediate the toxins released at their 12 artificial turf sports fields and compel them to replace those fields with natural grass.
This is especially urgent as RPD prepares to install 200,000 pounds of new turf at Minnie & Lovie Ward Park.
PUC owns the land at Crocker Amazon Park -- the Amazon Reservoir Tract. It is well within the PUC's rights to prevent RPD from transforming the 22.5 acres of remaining natural park into an artificial turf baseball complex managed by a public-private partnership with Crocker Amazon Project, LLC, a spin- off of the San Francisco Giants.
Thank you,
Susan Mullaney
Keep Crocker Real
1 From: Laura Handeland <[email protected]>
Sent: Saturday, June 13, 2026 9:42 PM
To: Commission
Cc: MelgarStaff (BOS)
Subject: Annual Goat Grazing Program at the Stanford Heights Reservoir This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Hello,
We love seeing the goats “mow” the reservoir here at Agua Way. Please let us know how we can help you with continuing the program.
Thanks,
--
Laura S. Handeland
[email protected]
74 Agua 94127
Sent on the run
Begin forwarded message:
From: Susan Friedman <[email protected]>
Date: June 13, 2026 at 11:16:57 PDT
To: Amy Mancasola <[email protected]>, Ellen Kerrigan <[email protected]>, Amy Shimm Noveshen <[email protected]>, Colby Mancasola <[email protected]>, herakim <[email protected]>, Baker Peeples <[email protected]>, Kim Hera Kyung <[email protected]>, Halie Kim <[email protected]>, Aaron Noveshen <[email protected]>, Lori Chang <[email protected]>, Andrew Huang <[email protected]>, [email protected], Maria Albaqurque <[email protected]>, Susie <[email protected]>, Gene Fitzer <[email protected]>, Cynthia Alvarez <[email protected]>, Ash Ley <[email protected]>, Jeanne Elliott <[email protected]>, [email protected], O'Neil Sarah <[email protected]>, Jose Guardado <[email protected]>, Adam Meredith <[email protected]>, Meredith Kremer <[email protected]>, Laura Handeland <[email protected]>, [email protected], [email protected], Kamyar Arbabifard <[email protected]>, Anne Scheeline <[email protected]>, [email protected], Jeanne Elliot <[email protected]>, Terry & Dede McDevitt <[email protected]>, Catherine Sparacino <[email protected]>, [email protected], [email protected], Sheila Kenney <[email protected]>, Hera Kim 2 <[email protected]>, Kyung Kim <[email protected]>, Lori Chao <[email protected]>, Paulo Albuquerque <[email protected]>, Susie Friedman <[email protected]>, Dorothy Pett <[email protected]>, [email protected], Sarah O'Neil <[email protected]>, Adam & Meredith <[email protected]>, Adam & Meredith <[email protected]>, Jesse Keen <[email protected]>
Subject: Annual Goat Grazing Program at the Stanford Heights Reservoir [email protected]
1 From: Amy Shimm Noveshen <[email protected]>
Sent: Tuesday, June 16, 2026 11:26 PM
To: Commission
Subject: Goat on Agua Way (Stanford reservoir)
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Hello! As a resident of Agua Way, I just want to let you know that we absolutely adore having the goats come and munch on the overgrown grass. Please continue this program! Amy Shimm
Amy Shimm-Noveshen, M.Arch.
Adjunct Faculty
City College of San Francisco
Visual Media Design Department
Office Hours for Spring 2026:
Wednesdays from 12–1 pm or by appointment.
www.ccsf.edu/vmd