Los Altos City Council
October 14, 2025

CITY COUNCIL MEETING
AGENDA
October 14, 2025 - 7:00 PM
In Person
PARTICIPATION: Members of the public are invited to participate by attending the meeting at the Los Altos Council Chamber, located at Los Altos City Hall, 1 N. San Antonio Rd, Los Altos, CA, during the meeting.

Public comments are accepted in person at the physical meeting location or via email to [email protected] or through the Public Comment forum on the city website: Public Comments Form.

RULES FOR CONDUCT: According to Los Altos Municipal Code, Section 2.05.010 "Interruptions and rules for conduct": Understanding that the purpose of the city council meetings is to conduct the people's business for the benefit of all the people, in the event that any meeting of the city council is willfully interrupted by a person or group of persons so as to render the orderly conduct of the meeting impossible, the mayor, mayor pro tem, or any other member of the city council acting as the chair may order the removal of the person or persons responsible for the disruption and bar them from further attendance at the council meeting, or otherwise proceed pursuant to Government Code Section 54957.0 or any applicable penal statute or city ordinance.

REMOTE MEETING OBSERVATION: Members of the public may view the meeting via the link below, but will not be permitted to provide public comment via Zoom or telephone. Public comments will be accepted in person, and members of the public may submit written comments by following the instructions below. https://losaltosca-gov.zoom.us/j/82009104171?pwd=Z29Xr8t3ltjqkyI4jdAvlaqQknDlpv.1 Telephone: 1-669-444-9171 / Webinar ID: 820 0910 4171 / Passcode: 542958 SUBMIT WRITTEN COMMENTS: Before the meeting, comments on matters listed on the agenda may be emailed to [email protected]. Emailed public comments sent directly to the City Council, either as a group or individually, will not be included in the agenda packet but may be disclosable as part of a public records request. Emails sent to [email protected] will be included in the appropriate agenda packet and are also disclosable as part of a public records request.

Please note: Personal information, such as e-mail addresses, telephone numbers, home addresses, and other contact information, is not required to be included with your comments. If this information is included in your written comments, it will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as submitted. Please do not include any information in your communication that you do not want to be made public.

Correspondence submitted via email must be received by 2:00 p.m. on the day of the meeting to ensure distribution prior to the meeting. Hard copy/paper format comments presented during the meeting will be distributed to the City Council the following day. Members of the public may present a copy of their comments or attachments to the City Clerk for distribution to the City Council. Any written or hard copy communications submitted after 2:00 p.m. on the day of the meeting will be added to the packet the next business day.

The Mayor will open public comment and will announce the length of time provided for comments during each item.

AGENDA

CALL MEETING TO ORDER

ESTABLISH QUORUM

PLEDGE OF ALLEGIANCE

REPORT ON CLOSED SESSION

CHANGES TO THE ORDER OF THE AGENDA

SPECIAL ITEMS
Issue Proclamation Recognizing October as Hindu Awareness and Appreciation Month

PUBLIC COMMENTS ON ITEMS NOT ON THE AGENDA
Members of the audience may bring to the Council's attention any item that is not on the agenda. The Mayor will announce the time speakers will be granted before comments begin. Please be advised that, by law, the City Council is unable to discuss or take action on issues presented during the Public Comment Period.

According to State Law (also known as “The Brown Act”) items must first be noted on the agenda before any discussion or action.
10-14-2025 Written Public Comments

CONSENT CALENDAR
These items will be considered by one motion unless any member of the Council or audience wishes to remove an item for discussion. Any item removed from the Consent Calendar for discussion will be handled at the discretion of the Mayor.

1. Approve Draft Meeting Minutes for the Regular Meeting of September 30, 2025

2. Adopt a Resolution Designating the City Council Meetings of November 18, 2025 and December 2, 2025 as Regular Meeting Dates in Accordance with Los Altos Municipal Code Section 2.04.010 "Meetings."
Adopt a Resolution Designating the City Council Meetings of November 18, 2025 and December 2, 2025 as Regular Meeting Dates in Accordance with Los Altos Municipal Code Section 2.04.010 "Meetings."

3. Adopt a Resolution recognizing October 19 - 25, 2025 as United Against Hate Week Adopt a Resolution recognizing October 19 - 25, 2025 as United Against Hate Week

4. Adoption of Resolutions - Addendum No. 13 to Regional Water Quality Control Plant Basic Agreement
Two actions for Council consideration:
• Adopt a Resolution Authorizing the City Manager to Execute Addendum No.13 to the Regional Water Quality Control Plant Basic Agreement between the City of Palo Alto, the City of Mountain View, and the City of Los Altos; and find that the Council’s action is exempt from review under CEQA pursuant to CEQA Guidelines Section 15301 and that none of the circumstances in CEQA Guidelines Section 15300.2 applies; and • Adopt a Resolution for the appropriation of $281,911 to the Sewer Operating Fund

5. Adoption of Resolution - Annual Streets Resurfacing Project Adoption a Resolution authorizing the City Manager to execute a professional services agreement with BKF Engineers for the FY2025-2026 Annual Street Resurfacing Project in the amount of $258,643.00 and authorize a project contingency of $25,864.00 for a total project amount not to exceed $284,507

6. Adopt Zoning Code Amendments - Historic Preservation & Mills Act Adopt the three (3) draft ordinances which include:
• An Ordinance of the City Council of the City of Los Altos Adding Chapter 14.93 (Historic Preservation) to the Los Altos Municipal Code; and
• An Ordinance of the City Council of the City of Los Altos Adding Chapter 14.95 (Mills Act Program) to the Los Altos Municipal Code; and
• An Ordinance of the City Council of the City of Los Altos Repealing in its Entirety Chapter

12.44 for Existing Historic Preservation Regulations; and • Find that the proposed amendments are exempt from environmental review pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines

7. Adoption of Resolution - Amend Contract with Los Altos Chamber of Commerce Amend contract with Los Altos Chamber of Commerce

PUBLIC HEARING

8. 2025 Los Altos Building Code Updates
Three separate actions for Council consideration:
• Introduce an Ordinance of the City Council of the City of Los Altos Repealing in its Entirety Title 12 for Buildings and Construction of the Los Altos Municipal Code; and • Introduce an Ordinance of the City Council of the City of Los Altos Adding Title 12 for Buildings and Construction to the Los Altos Municipal Code Including Chapters 12.04,

12.06, 12.08, 12.10, 12.12, 12.14, 12.16, 12.18, 12.20, 12.22, 12.24, 12.26, 12.28, 12.30,

12.32, 12.34, 12.36, 12.38, and 12.40 to Adopt by Reference the 2025 California Building Codes with Local Amendments; and Find that both actions are exempt from environmental review pursuant to Section 15061(b)(3) and 15308 of the California Environmental Quality Act (CEQA) Guidelines; and
• Direct staff to place the introduced Ordinances on the October 28, 2025, meeting agenda for a public hearing, waiving of second reading, and adoption.

DISCUSSION ITEMS

9. Approve the formation of a Subcommittee of the City Council for the Annual City Manager Performance Review
Approve the formation of a Subcommittee of the City Council for the Annual City Manager Performance Review

10. Dog Park Surfacing Discussion
Staff recommends the City Council direct staff to complete one of these options:
1) Proceed with the Callander and Associates 95% submittal to construct the Hillview Dog Park using the synthetic turf ground covering as approved at the July 9, 2024 City Council meeting; or

2) Return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering, and further direct staff to complete the proposed McKenzie Dog Park while Hillview Dog Park is proceeding through redesign.

11. Authorize the City Manager to Issue Formal Bid for Woodland Library Patio Expansion Plan and find that the proposal is exempt from environmental review pursuant to California Environmental Quality Act Section 15301 (Existing Facilities consisting of the minor alteration of existing public structures and facilities) Authorize the City Manager to Issue Formal Bid for Woodland Library Patio Expansion Plan and find that the proposal is exempt from environmental review pursuant to California Environmental Quality Act Section 15301 (Existing Facilities consisting of the minor alteration of existing public structures and facilities)

INFORMATIONAL ITEMS / COUNCIL Q&A
There will be no discussion or action on Informational Items. The Council Q&A will be included in the packet the day of the meeting.

12. Tentative Council Calendar and Housing Element Update Implementation Calendar

13. 10-14-2025 Council QA
COUNCIL/STAFF REPORTS, REQUESTS FOR FUTURE AGENDA ITEMS & AB1234 REPORTS

ADJOURNMENT
(Council Norms: It will be the custom to have a recess at approximately 9:00 p.m. Prior to the recess, the Mayor shall announce whether any items will be carried over to the next meeting. The established hour after which no new items will be started is 11:00 p.m. Remaining items, however, may be considered by consensus of the Council.)

SPECIAL NOTICES TO THE PUBLIC
According to the City Council Norms and Procedures: It will be customary to have a recess at approximately 9:00 p.m. Before the recess, the Mayor shall announce whether any items will be carried over to the next meeting. The established hour after which no new items will be started is 11:00 p.m. Remaining items, however, may be considered by consensus of the Council.

In compliance with the Americans with Disabilities Act, the City of Los Altos will make reasonable arrangements to ensure accessibility to this meeting. If you need special assistance to participate in this meeting, please get in touch with the City Clerk at least 72 hours before the meeting.

All public records relating to an open session item on this agenda, which are not exempt from disclosure according to the California Public Records Act, and that are distributed to a majority of the legislative body, will be available for public inspection at the same time that the public records are distributed or made available to the legislative body.

From: Steve Smith
To: Public Comment
Subject: Hillview Dog Park Surface-Mtg 14 Oct, 2025
Date: Tuesday, October 7, 2025 9:13:32 AM
Dear COuncil Members,
I am writing to object to the use of Artificial Turf. This material gets very hot in the sun, cooks the soil, and does nothing for the environment.

If you want something that is dog paw dig proof, enhances the soil, is cool to the touch, and absorbs odors, I recommend that you
A) Do appropriate soil prep,
B) Spread grass seed--SHOCKING, I KNOW
C) Lay out 1/4" heavy duty plastic coated hot dip galvanized (after welding) mesh
to make the field dog paw dig proof (30 year in ground life, 20 gauge metal, 18 gauge after coating). The only supplier of quality mesh is critterfence, link is here:
https://www.critterfence.com/critterfence-1-4x1-4-black-welded-wire-fence NOTE: Last year they made an even heavier duty version, may be special orderable.

D) Cover with 1/2 inch of good soil
E) Water and watch the grass grow.

Kindly forward to the appropriate city employee.

Regards,
Steve Smith
1914 Annette Ln

From: [email protected]
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Date: Tuesday, October 7, 2025 12:18:49 PM
Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Please keep the current Hillview Dog Park! Artificial turf is an unnecessary cost that will result in more work to maintain.

Additionally, the smell that develops with dogs on artificial turf will become unbearable for park and library guests.

Attachments Field not completed.

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From: Roberta Phillips
To: City Council; Public Comment
Subject: City Council Meeting Oct 14, 2025 Item # 5
Date: Thursday, October 9, 2025 1:18:18 PM
Attachments: City Council Meeting Oct 14 Historic Preservation.docx Dear Council Members , Mayor and City Manager
Please see the attached letter
Thanks
Roberta Phillips
650-941-6940

City Council Meeting Oct 14,2025 Item #5
Dear Council Members
I would like you to consider pulling Item #5 (Historic Preservation and Mills Act) to discuss and take a new vote on the Blue Line Version. I understand that the Blue Line Version was added to provide a compromise that was agreed upon by the Historic Property Owners and Staff. I believe you have the votes. Although the changes in the Blue Line Version are minor this would be a win – win situation where a compromise was reached to include input from the community, showing respect for the Council as well as residents who cherish our historic resources.

Sincerely
Roberta Phillips

1 Melissa Thurman
From: Roberta Phillips <[email protected]>
Sent: Thursday, October 9, 2025 4:13 PM
To: Public Comment
Subject: City Council Meeting Oct 14th Item #5
City Council Meeting Oct 14,2025 Item #5
Dear Council Members
I would like you to consider pulling Item #5 (Historic Preservation and Mills Act) to discuss and take a new vote on the Blue Line Version. I understand that the Blue Line Version was added to provide a compromise that was agreed upon by the Historic Property Owners and Staff. I believe you have the votes. Although the changes in the Blue Line Version are minor this would be a win – win situation where a compromise was reached to include input from the community, showing respect for the Council as well as residents who cherish our historic resources.

Sincerely
Roberta Phillips

1 Melissa Thurman
From: Pat Marriott <[email protected]>
Sent: Thursday, October 9, 2025 4:58 PM
To: Public Comment
Subject: PUBLIC COMMENT ITEM #6 OCTOBER 14, 2025
Council Members:

Please pull item #6 from the Consent Calendar.

There is still a great deal of confusion about PUBLIC historic properties.

Some people think only residents within 300 feet could voice opinions.

Some have said any resident could have input – in an appeal situation.

Some think a change to such properties would go to the Historical Commission and then directly to Council for a decision.

However, the city manager says, “This process may include the Historic Commission or Planning Commission or both prior to reaching Council."
I would like to see a step-by-step outline of what would happen if changes were proposed for any public historic property. (Not an appeal after a decision is made. The code should be written in a clear and consistent manner so that a good decision is made – with all required input and reviews – the first time around.) I don’t even know what Step 1 would be. Let’s take Halsey House as an example. That’s been kicked around for years. Could Nick Zornes propose some action? Council member? Commissioner? Resident? What happens next? Does the proposal then go to Nick Zornes to shepherd through the process? This topic needs clarification before Council signs off on the final changes.

Thank you,
Pat Marriott

Recycle company’s bankruptcy leaves tons of
discarded artificial turf across the state
The turf, laden with forever chemicals, now faces an uncertain future. by Barbara Laker and David Gambacorta
Published Sept. 30, 2025, 5:00 a.m. ET
It was supposed to be Pennsylvania’s Green Dream.

Re-Match, a Denmark-based recycling company, had planned to open what it said would be the first artificial turf recycling facility in the United States — in a Schuylkill County factory by the end of 2024.

Environmentalists were overjoyed. Lab tests have shown that artificial turf has for decades contained PFAS, or per-and polyfluoroalkyl substances. The so-called forever chemicals — which are found in an array of products, including and nonstick cookware —
don’t break down in the environment and have been linked by the EPA to cancer, asthma, thyroid disease, and decreased immunity to fight infections.

But Re-Match’s recycling dream will never be realized in Pennsylvania and as a result, tons of chemical-laden turf pose an ongoing environmental threat with no easy solution.

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In June, the company filed for bankruptcy in the U.S. Bankruptcy Court for the District of Delaware, bringing to end a company whose arrival in Pennsylvania was once celebrated by top elected officials.

Re-Match had, in recent years, stored in
three locations across the state, including a farm in Nicholson, Wyoming County, where nearly 6,000 tons of old turf sit on dirt fields. The turf, once meant to be recycled, now faces an uncertain future.

Environmental experts say that Re-Match’s abandoned rolls are emblematic of a larger problem. For years, municipalities and subcontractors have dumped old turf in warehouses, waterways, and wooded areas across the state. Neither the full amount nor the location of the discarded turf has been tracked by the state’s Department of Environmental Protection (DEP).

For the discarded turf that is on its radar, the agency must determine how and where to dispose of it.

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“We’re all going to suffer because these turf fields — particularly the old ones, which we know have PFAS — are going to leech off and contaminate farmers’ fields, groundwater, drinking water supplies, and surface waters,” said Kyla Bennett, a former EPA official who is now science policy director for Public Employees for Environmental Responsibility (PEER).

She added that she’s not surprised that the Re-Match project in Pennsylvania failed.
“It’s cheaper for these artificial turf companies to just dispose of it another way,” Bennett said.

Former Re-Match executives declined to answer questions for this article.

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Turf recycling is still largely a nascent industry, and in a 2021 investor prospectus Re-Match disclosed potential financial threats, from an inability to recycle 100% of the turf it collected, to possible environmental contamination that could have been caused by its recycling operations.

Another obstacle is the turf industry itself, according to Bennett and other environmental activists, who say that some turf companies are not committed to having their products recycled.
“The synthetic turf industry is in the business of selling artificial grass.

They’re not interested in reducing plastic pollution, so whatever is going to be financially beneficial for them is what they’re going to do,” said Diana Carpinone, president and co-founder of Non Toxic Communities, a national nonprofit that supports local efforts to eliminate toxic chemicals.

Melanie Taylor, president and CEO of , a
national organization that represents manufacturers, builders, and infill material suppliers, rejected those claims. In an email to The Inquirer, she wrote that its “members are investing in innovative recycling and reuse solutions to reduce landfill reliance and advance a circular economy.”

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She declined to comment on Re-Match, but noted that in Rockland, Mass., about 21 miles outside Boston, a company called Turf Recycling USA is successfully recycling old artificial fields.

The company has been in operation for just two months. Robert Delmonico, Turf Recycling’s president and CEO, told The Inquirer it has received about eight turf fields that it intends to recycle.

Machines separate the rubber and sand infill, clean and process it, and sell it to rubber or turf companies for future use. Other machines churn the green carpet into plastic pellets, which are then sold to plastic companies to make products like outdoor tables and chairs, benches and bins, he said.
“Re-Match made it very difficult for anyone attempting to recycle turf because they failed,” said Delmonico, who also serves as the president of R.A.D. Sports, which sells artificial and natural athletic fields. “You learn from other people’s mistakes.”

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Asked if he was worried about PFAS making its way into another product, he said, “We’re not trying to solve the PFAS issues. We’re trying to prevent products from going to landfills.”
Re-Match’s outlook once seemed promising.

In 2021, Pennsylvania’s then-governor, Tom Wolf, announced that ReMatch offered a “sustainable solution” to the problem of old turf fields, which he said posed a “significant challenge to the environment.” Re-Match planned to operate 24 factories in multiple countries by 2031.

Its recycling procedures had been given a stamp of approval by an independent body, the European Union’s
program.

Re-Match claimed that by recycling turf — instead of burning it — the Pennsylvania facility would spare the environment from 100,000 tons of carbon dioxide.
“I do think that Re-Match’s heart was in the right place and that they wanted to solve this problem,” Bennett said.

There are between 18,000 and 19,000 synthetic turf fields in the United States, with 1,200 — 1,500 new installations each year, and about half those are replacements, according to a recent EPA report.

While Re-Match waded through the process of obtaining necessary operating permits, the company signed agreements to pay thousands of dollars to Pennsylvania farmers, and at least one small business, to store hulking rows of old turf on their properties.

Those arrangements proved to be problematic.

At least two farmers claimed in court filings that Re-Match stopped paying them, and the DEP received complaints about the unsightly stacks.

In June 2018, Re-Match agreed to begin paying more than $96,000 a year to Benedict “Benny” Diaz, the owner of B.D. Hill Side Farm in Wyoming County, to store old turf on his land.

The company went on to deposit more than 400 tractor-trailer loads of turf on the farm before allegedly stopping payments in 2019, according to a federal lawsuit that Diaz later filed against Re-Match. Diaz claimed the company owed him nearly $300,000.

In November 2023, the case was settled, but the parties did not disclose the terms. Diaz died in July this year, and his son is consulting with a lawyer on how to rid the farmland of the remaining turf rolls. “I have to figure it out with the DEP,” the son, Benny Diaz, said. “I don’t want it. I want it out of there, because it’s nothing but a nuisance and a headache for me.”
The DEP has categorized the old turf as “solid waste” that constitutes a “public nuisance,” and further determined that Re-Match by failing to obtain necessary permits for storing the
turf.

When Re-Match filed for bankruptcy, it owed the state $19,500 in fines.

In a 2023 consent order with DEP, Re-Match agreed to establish a $644,000 bond in case it failed to remove or recycle the turf.

Re-Match has left 2,360 tons of turf at the factory it had rented in Tamaqua, Schuylkill County. Another 2,600 tons sit next to a concrete company in Jonestown, Lebanon County, and almost 6,000 tons are piled high on the Diaz farm in Nicholson.
“This bond remains in place and is expected to fully cover the cost of processing the remaining stock in the area,” said Dennis Andersen, former president of Re-Match.

But according to Re-Match’s bankruptcy filing, the Nicholson cleanup alone is estimated to cost $683,008.

The DEP is in the process of developing a cleanup plan for the Tamaqua site, said John Repetz, the agency’s regional communications manager.

After that site is cleaned, the spokesperson said, “any remaining forfeited bond money will go toward cleaning up the other two sites.” Artificial turf was pioneered and sold in the late 1960s by the Monsanto Chemical Co., as an affordable and effective way to provide children and professional athletes with durable, outdoor playing surfaces.

Once called the “Magic Carpet,” industry representatives tout how the turf saves money on water, doesn’t require pesticides, and reduces maintenance costs.

It wasn’t until 2019 that independent scientists discovered that the green carpets contained PFAS.

In March 2023, an Inquirer investigation, found that
AstroTurf that covered the field at Philadelphia’s Veterans Stadium in the late 1970s and early 1980s contained 16 different types of PFAS.

Six former Philadelphia Phillies who spent at the
Vet between 1971 and 2003 have died from glioblastoma — about three times the average rate of this aggressive form of brain cancer among adult men in the U.S. (The Phillies have said that several brain cancer experts have told the organization that there is no evidence of a link between artificial turf and the disease.)
Some turf companies claim that they now produce PFAS-free turf products, but those promises have been by
independent scientists.

In recent years, when some schools and municipalities have debated the potential long-term costs of new turf fields,
that the products can be recycled. But that is another unproven claim said Bennett, the former EPA official.
“No one has been able to give us an address of a facility that is recycling these fields into a product,” Bennett said. “All we are told is that it exists with no evidence.”
Some bundles of used turf have found a second life in online marketplaces, where they’re sold and used to carpet batting cages, dog runs, backyards, miniature golf courses, and paint-ball fields.

Some community activists and environmentalists have tracked discarded turf.

The Inquirer found in 2023 that 15 trucks hauling 228 rolls arrived at a warehouse in Pottstown from Newtown, Mass., according to a chain of custody document.

That warehouse, operated by Allen Waterman, owner of APW Enterprises, recycles sand and crumb rubber from used turf fields.

The sand and rubber would be bagged and sold to the turf industry or other manufacturers, Waterman had told The Inquirer.

Waterman said he sends all the carpet to “partners,” who would extrude the carpet into new plastic lumber products. When a reporter asked him who the partners were, he replied: “None of your business.” In Portsmouth, N.H., the Portsmouth School District paid a Massachusetts company $51,000 to remove 243 tons of field turf and have it recycled in July 2023.

But Carpinone, who lives in Dover, N.H., tracked the old turf to an abandoned warehouse in Franklin, N.J., with no signs of recycling equipment.
“The utilities had not even been turned on. They never moved in,” Carpinone said.

She found the turf listed for sale on Facebook Marketplace. “Other people that have followed fields find that they haven’t been recycled either. I don’t think this is an isolated incident. I think this is business as usual for the synthetic turf industry,” she said.

Some recycling facilities, like the ExxonMobil plant in Baytown, Texas, process plastic waste by burning it.
“It’s a euphemism that the plastic and fossil fuel industry want people to think that it’s recycling, but it’s not,” Bennett said. “It’s all smoke and mirrors.”
But the promise of recycling is enough for these municipalities,” Bennett said.
“When the turf company goes into a town and says we’re going to recycle it, everybody believes it’s going to be recycled,” she said. “They believe they’re doing something good for the environment. They don’t question it. It’s very frustrating for all of us who know the truth.” Barbara Laker
I work on the investigations team, where I dig deep into a host of topics, hoping to break new ground and uncover injustice and corruption.

David Gambacorta
I am a reporter and editor on The Inquirer's Investigations team. I work on projects that explore accountability themes in a wide array of topics that impact the Philadelphia region.

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NEWS
Monica Herndon / Staff Photographer
Almost 6,000 rolls of artificial turf sit on the farm of the late Benedict Diaz in Nicholson, Pa. ReMatch, a now-bankrupt recycling firm, has left them here. Now the state's Department of Environmental Protection has to figure out how to dispose of it.

Listen to article • 13:24 min
Failed promises
Monica Herndon / Staff Photographer
Almost 6,000 rolls of artificial turf remain on the farm of the late Benedict Diaz in Nicholson, Pa.

Diaz's son is reaching out to the state's Department of Environmental Protection to find a way to get rid of it.
‘Smoke and mirrors’
Julia Malakie
In July 2023, a trucking company worker tosses a strap to secure rolls of old artificial turf from a high school football field in Newton, Mass. The turf was shipped to Pottstown, Pa.

Obtained by The Philadelphia Inquirer
Some 243 tons of old artificial turf removed from Portsmouth High School in New Hampshire ended up in a Franklin, N.J., warehouse in 2023.

Acknowledgment
The Inquirer's journalism is supported in part by The Lenfest Institute for Journalism and readers like you. News and Editorial content is created independently of The Inquirer's donors. Gifts to support The Inquirer's high-impact journalism can be made at inquirer.com/donate. A list of Lenfest Institute donors can be found at lenfestinstitute.org/supporters.

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firefighting gear
11,000 tons of decaying turf rolls
The Synthetic Turf Council
Environmental Technology
Verification
violated state
environmental laws
“Field of Dread,”
parts of their careers
disproved in some instances
manufacturers have assured
them
To: Los Altos City Council
From: Peter Landsberger
Subject: Public Comment - Item 10. Dog Park Surfacing Discussion Dear Council Members,
A representative of the Synthetic Turf Council is quoted in this article as saying, “members [of the council] are investing in innovative recycling and reuse solutions to reduce landfill reliance and advance a circular economy.” This article describes the reality.

The current Hillview dog park plan is flawed. Please eliminate synthetic turf as an option for ground covering.

1 Melissa Thurman
From: Andrea Wald <[email protected]>
Sent: Thursday, October 9, 2025 9:14 PM
To: Public Comment
Subject: Agenda item #10 - 10/14/25 city council meeting Dear Mayor and City Council members,
You've heard from me many times so I will not repeat all the reasons why I strongly oppose artificial turf - both for the dog park and any landscape projects (parks, schools, even residential and commercial).

I am simply emailing now to urge you to approve recommendation #2 that is under agenda item #10:
2) Return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering, and further direct staff to complete the proposed McKenzie Dog Park while Hillview Dog Park is proceeding through redesign.

I believe this is the best option and what not only residents of Los Altos need and want but what is best for society as a whole. We are drowning in unnecessary plastics - artificial turf being one of those products.

Please keep in mind things like: sustainability, environmental impact, health implications, waste and Los Altos' own Climate Action goals when casting your important vote.

Thanks.

Andrea Wald
Co-Founder, Community for Natural Play Surfaces

1 Melissa Thurman
From: Nyssa Kansal <[email protected]>
Sent: Thursday, October 9, 2025 9:22 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
To the City of Los Altos:

I urge the city council to either a) require decomposed granite as the surface for the dog park, and exclude artificial turf OR b) vote the entire plan down so it can be brought back to a future meeting for consideration.

Sincerely,
Nyssa

1 Melissa Thurman
From: Brian Carr <[email protected]>
Sent: Thursday, October 9, 2025 9:26 PM
To: Public Comment
Subject: Oct 14 Meeting, Item 10, Hillview Dog Park Surface I urge you to reject the use of plasƟc turf at the Hillview Dog park. Every use of plasƟc, mulƟplied by tens of thousands, is an assault on our environment and health. Please vote for opƟon #2,
Brian Carr

Los Altos City Council Members,
Re: 10/14/25 Meeting Agenda Discussion Item #10 Dog Park Surfacing I am a longtime resident and member of the Silicon Valley North Chapter of the Citizens’ Climate Lobby (CCL). In this letter I represent myself as a concerned community member.

I support the Los Altos Rotary Club’s ongoing eƯorts to promote the use of natural materials for the Hillview dog park surface and encourage the city to adopt a policy prohibiting artificial turf surfacing in all city properties. The basis for my support is the city’s Climate Action & Adaptation Plan (CAAP) adopted by the city in 2022.1
The Rotary Club’s Climate Action Committee initiative on the dog park and its position on artificial turf is directly pertinent to CAAP’s Focus Area 5 Green Community Strategy 1 Develop Nature Based Solutions.

Nature Based Solution
1 City of Los Altos Climate Action & Adaptation Plan link:
https://www.losaltosca.gov/DocumentCenter/View/851/Los-Altos-Climate-Action-andAdaptation-Plan-2022-Final-PDF

CAAP’s goal is to achieve carbon neutrality by 2035. It is an ambitious, multifaceted, forward-looking plan that, if implemented, would be the closest thing to a comprehensive local climate solution that we need to achieve nationally.

Numerous CAAP provisions rely on Inflation Reduction Act legislation that I pushed for in 2022 as a citizen advocate with Congress.

I have been active in supporting CAAP’s electrification provisions working with the Electrification Collaboration initiative. We measure our eƯorts in the context of CAAP’s success in total. Putting it another way, our local advocacy impact will be limited if electrification succeeds but CAAP fails.

Other community organizations, such as Green Town Los Altos and the Los Altos Rotary Club are supporting diƯerent facets of CAAP. The Electrification Collaboration is an integral part of this on-going community-wide CAAP success coalition.

Thank you for your consideration.

David Cain PhD
1132 Russell Ave. Los Altos

1 Melissa Thurman
From: Laura Fay <[email protected]>
Sent: Friday, October 10, 2025 1:00 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Mayor Daley, Vice Mayor Fligor and Councilmembers Lang, Meadows and Weinberg, I am writing to request that you REJECT THE INSTALLATION OF ARTIFICIAL TURF at the Hillview Dog Park in favor of a more environmentally sustainable surface for the sake of citizen, canine and environmental health. I make this request with consideration for ODOR ISSUES stemming from artificial turf. I will run through the reasons here....

1. In 2023 the Verde Design/Staff Community outreach revealed that 'Odor control' ranked as a key concern

2. Experience for Library and History Museum Attendees May be Sub-optimal Foul smells from the artificial turf offers the potential for the bad odors to waft from the dog park in the direction of the library and the history museum. This would not be ideal for library goers or those that rent the history museum for events like weddings in the warm summer months.

3. Community Experience
I have personally visited dog parks in and around the Bay Area, the most recent being teh Ana Antonio Dog Park in Mountain View. Standing inside that park for 5 minutes was barely tolerable.

The dog owners told me that "the smell wasn't too bad that day, because it had rained briefly in the morning. Try coming on a sunny day, it's truly awful."
Many current Hillview park dog owners and Hillview Avenue residents have indicated that they are very concerned about the potential for bad smells

2 4. High maintenance cost and water usage to mitigate
A search on Google/Gemini summarises the documented reasons for the bad smells, and what's required to stay on top of the issue. It is clearly not a low maintenance or low water usage situation...

Artificial turf can smell bad due to pet urine trapped in the infill, which releases ammonia, or from bacteria and mold that grow when organic matter and liquids like rain or urine build up due to poor drainage. High heat can intensify these odors by causing the turf's materials to off-gas and by increasing the release of ammonia from urine. Regular cleaning with enzyme-based products, addressing drainage issues, and promptly removing waste are key to preventing and eliminating these smells.

Reasons for Bad Smells
 Pet Urine:

Dog urine contains urea and ammonia, which break down and release a strong, unpleasant odor when left on the turf.
 Poor Drainage:

Insufficient drainage can trap liquids and organic matter, creating a moist environment where mold and mildew thrive and produce musty smells.
 Bacteria and Mold:

Accumulation of dirt, dust, pet waste, and other organic matter provides a food source for bacteria and mold, which contribute to odors.
 Heat and Off-Gassing:

High temperatures can cause the synthetic materials in the turf to release volatile organic compounds (VOCs).
 Trapped Infill:

The infill (the material between the turf blades) can absorb and hold liquids, including pet urine, trapping the smell and making it hard to remove.

How to Prevent and Eliminate Smells
 Use Enzyme-Based Cleaners:

These cleaners contain beneficial enzymes and bacteria that break down the source of the ammonia in pet urine.
 Ensure Proper Drainage:

A well-installed turf system with effective drainage allows liquids to pass through, preventing them from pooling and fostering bacterial growth.
 Regular Cleaning:

3 Periodically hose down the turf and clean it with a mixture of vinegar and soap or an enzyme cleaner to eliminate built-up dirt and odors.
 Remove Pet Waste Promptly:

Regularly pick up pet waste and rinse the area with water to prevent urine from soaking into the turf.
 Maintain Infill:

Over time, the infill can become dirty and hold odors. Regular cleaning and topping up the infill can help.

Please do the right thing and reject the installation of artificial turf.

Sincerely,
Laura Fay

1 Melissa Thurman
From: Bruce England <[email protected]>
Sent: Friday, October 10, 2025 2:17 PM
To: Public Comment
Cc: Bruce England
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear City Council members:

Please count me as one member of community who is against use of artificial turf anywhere it might be installed, including in dog parks. I should note also that I'm a dog owner and walker, and they seem far less inclined to explore plastic grass than they are natural growth, which, as you know, is something that makes dogs particularly happy.

Best regards,
Bruce England
328 Whisman Station Drive
Mountain View, CA 94043

1 Melissa Thurman
From: rmloui <[email protected]>
Sent: Friday, October 10, 2025 3:10 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 - Dog Park Surfacing Discussion - Mtg 10/14/2025 Dear Los Altos City Council,
With regards to Agenda #10 for the upcoming meeting on Oct 14th, I am writing to object to the installation of artificial turf. This material is a health and environmental hazard to both humans and their pets. Natural materials should be used instead, not fossil-fuel derived plastic.

We should not repeat the mistake that was done at the Village at San Antonio Center Dog Park. That dog park is unpleasant, and I do not take my dog there for multiple reasons: bad smell, unsanitary, high heat retention that is painful or uncomfortable for dog paws, rough material that is abrasive to tender paws, plastic off-gassing.

Please reject artificial turf at the Hillview Dog Park and instead select a more environmentally sustainable and responsible surface.

Thank you for your consideration.

Best regards,
Rachel Loui
Mountain View, CA

1 Melissa Thurman
From: Leslie Friedman <[email protected]>
Sent: Friday, October 10, 2025 5:16 PM
To: Public Comment
Subject: artificial ground covering
Hello,
I am not a Los Altos resident, but I would like to share my experiences.

I am a baseball fan (St.Louis Cardinals especially). I know that that company removed its grass and replaced it with artificial stuff. After years of damage to
the professionals' feet, legs and arms because of the artificial surface, the team finally removed it. This happened to many many professional teams.

The artificial turf becomes too hot. The athletes burned their feet. If they slided into a base, they would have bruises and burns on their bodies. It was
always too hot for the players.

Here's what I do not understand: if the professionals realized that the artificial turf is not only too hot and also too hard, Why would anyone encourage placing this artificial turf for children? The material is toxic. Why allow your children
and your beloved dogs to play on toxic material?
Some people think that it is a way to save money, but hospital care is expensive.

Please stop the artificial turf.

Leslie Friedman, Ph.D.

1 Melissa Thurman
From: Quinten Yearsley <[email protected]>
Sent: Friday, October 10, 2025 6:17 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Los Altos Council Members,
I had sent an email earlier for comment on this matter for the earlier meeting (Aug 26) when it was discussed.

I would just like to reiterate and say that in general, I urge the council to prioritize environmental impact as a factor for consideration when making decisions. In this case, as far as I understand, decomposed granite (and maybe some of the other choices) are probably a better choice than artificial turf.

Keep up the good work and thank you,
Resident Quinten Yearsley

1 Melissa Thurman
From: Leslie Allanic-Desaeyere <[email protected]> Sent: Friday, October 10, 2025 6:53 PM
To: Public Comment; L E S L I E
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Attachments: Flier - No on AT - Oct 14 2025.docx
 I strongly object to to exposing the humans and pets to the hazards of Artificial Turf . I am from europe and most artificial turf is being removed because so many children especially goal keepers are getting cancer.

I Request the city council REJECT artificial turf at the Hillview Dog Park and select a more environmentally sustainable surface for the sake of citizen and canine heath.

Thanks
Leslie Desaeyere
----- Forwarded Message -----
/d/msgid/greenspacesmv/CAOh0-
R06t5OF4oG%3D88j3a_SG%3D6UK6x%2BgOOL%2BGVT8dSmjyeU9SQ%40mail.gmail.com.

JUST SAY NO to the installation of ARTIFICIAL TURF at the Hillview Dog Park WHY? TAKE ACTION
Unpleasant Experience
• Unsanitary
• Foul odor*
• Chemical cleaning
• Excessive heat
Health Risk
• PFAS exposure linked to cancer
Environmental Hazard
• Microplastic runoff
• High carbon manufacturing
• Landfill waste
• ‘Heat island’ effect
• High water needs (cleaning)
Other
• High Cost to install and maintain
OCT 12 & 13: SEND EMAIL
• To: [email protected]
• Subject: Public Comment Agenda item
#10 – Dog Park Surfacing Discussion - Mtg
Oct 14, 2025
• Content: State your objection to exposing
the humans and pets to the hazards of
Artificial Turf. Request the city council
REJECT artificial turf at the Hillview Dog
Park, and all city dog parks.

Oct 14: ATTEND IN PERSON
Join the visible display of support at the City
Council Meeting
• Tuesday, Oct 14th at 7:00pm
• City Hall, 1 N San Antonio Road, Los Altos
*To experience how stinky an AT dog park can be, please stand in the Village at San Antonio Center Dog Park for 10 minutes.

1 Melissa Thurman
From: Danielle Schmitz <[email protected]>
Sent: Saturday, October 11, 2025 9:30 AM
To: Public Comment
Subject: Enhancing Dog Park Safety and Health with Synthetic Turf Dear City Council Member/Committee Name,
I am writing to urge the city to consider synthetic turf for our dog parks as a safe, hygienic, and longlasting surface. Unlike dirt or decomposed granite, synthetic turf can reduce mud, standing water, and bacterial buildup, which helps prevent illness among dogs and promotes a healthier park environment for the community.

With a regular cleaning and sanitizing schedule, synthetic turf ensures that our parks remain safe, clean, and enjoyable year-round. This investment would not only improve the health and safety of our pets but also enhance the overall experience for park visitors.

Thank you for considering this important public health and safety measure. I would be happy to provide more information on maintenance protocols or examples from other municipalities that have successfully implemented synthetic turf in dog parks.

Sincerely,
Danielle
--
Danielle Schmitz
(650) 996-1608
418 Tyndall St., Los Altos, CA

1 Melissa Thurman
From: Laura Fay <[email protected]>
Sent: Saturday, October 11, 2025 12:02 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Mayor Daley, Vice Mayor Fligor and Councilmembers Lang, Meadows and Weinberg, I am writing to request that you listen to the community and REJECT THE INSTALLATION OF ARTIFICIAL TURF at the Hillview Dog Park in favor of a more environmentally sustainable surface for the sake of citizen, canine and environmental health. I make this request for the following reasons....  The 2023 outreach and surveys conducted by Vered Design/City Staff indicated that natural grass was the preferred surface for the dog park by the community outreach efforts (reference council meeting presentation on July 9th. 2024)
 A 2025 Town Crier survey, open for over three weeks, shows a clear preference for natural grass at 61% of respondents, with artificial turf a distant third preference (as of my time of writing, the poll is still open here. Once taken the results are displayed. o
 Conversation with over a dozen dog owners at the current temporary Hillview Dog Park (which is natural grass), revealed that they overwhelmingly prefer a natural surface, and specifically are against artificial turf. Don't just take my word for it. Please visit there and invite the conversation, or send city staff to have the conversation.

Thank you,
Laura Fay
30-year Los Altos resident

1 Melissa Thurman
From: [email protected]
Sent: Saturday, October 11, 2025 1:26 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Please do not use artificial turf for dog parks. They are chemical laden, get too hot, do not absorb dog urine odors.

There are more Eco-friendly alternatives including paving stones, native grasses and ground covers or just regular grass.

Attachments Field not completed.

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1 Melissa Thurman
From: Rashmi Sahai <[email protected]>
Sent: Saturday, October 11, 2025 1:35 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Los Altos City Council,
I am writing to urge you to vote against using artificial turf to construct Hillview Dog Park (agenda item #10 at Tuesday's City Council meeting). Instead please vote for option #2: "Return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering, and further direct staff to complete the proposed McKenzie Dog Park while Hillview Dog Park is proceeding through redesign."
Artificially turf is not only bad for the environment, as it provides no biodiversity or stormwater benefits, but the chemicals used for artificial turf are also toxic to human and canine health.

Thank you for your consideration.

Best,
Rashmi Sahai

The City Council meeting agenda for Tuesday Oct 14 at 7pm is now published. Packet here: https://losaltosca.portal.civicclerk.com/event/183/files/agenda/1295 The agenda item is #10 "Dog Park Surfacing Discussion: Staff recommends the City Council direct staff to complete one of these options":

1. Proceed with the Callander and Associates 95% submittal to construct the Hillview Dog Park using the synthetic turf ground covering as approved at the July 9, 2024 City Council meeting; or

2. Return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering, and further direct staff to complete the proposed McKenzie Dog Park while Hillview Dog Park is proceeding through redesign.

We need to influence the council to vote for option #2, so PLEASE...

1. SEND AN EMAIL NOW
 To: [email protected]
 Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
 Content:
oState your objection to exposing the humans and pets to the hazards of Artificial Turf (feel free to expand on this as you see fit).

2 oRequest the city council REJECT artificial turf at the Hillview Dog Park and select a more environmentally sustainable surface for the sake of citizen and canine heath.  Note: All comments received at least a day before the meeting are typically read by all the council members in advance of the meeting. Also, these emails become part of public record, ensuring that the citizens’ sentiment is on record.

2. ATTEND IN PERSON

1 Melissa Thurman
From: Tracy Ferea <[email protected]>
Sent: Saturday, October 11, 2025 1:36 PM
To: Public Comment
Subject: Agenda Item #10 – Dog Park Surfacing Discussion Dear Council Members,
Please do NOT install artificial turf in the dog park. It is toxic and we would like you to support a more sustainable option for both us and our dogs.

Thank you,
Tracy F PhD

1 Melissa Thurman
From: Susan Hinton <[email protected]>
Sent: Saturday, October 11, 2025 4:38 PM
To: Public Comment
Subject: Public Comment on Oct. 14, 2025 Agenda #10 Dog Park Surfacing Discussion Dear Los Altos Mayor Dailey, Vice Mayor Fligor, and Honorable Councilmembers, I am a dog owner, a Sierra Club member, and a resident of of the San Francisco South Bay area since 1989, and I urge the City of Los Altos to put in natural surfacing at their dog parks, rather than plastic.

As a dog owner of a 10 year old happy, mix-breed 65 pound ball of fur, I have visited many dog parks throughout the South Bay. Our family’s favorite dog park is in the 17 acre off-leash area at the top of Redwood City’s Pulgas Ridge Open Space Preserve. Those acres are not irrigated. Dog owners are asked to pick up remains and remove them from the park. Amazingly close to 100% of dog owners comply with this simple request. The dogs don’t care whether they are on a dirt trail, a grass or dirt field, or in the middle of brush. They simply enjoy being off-leash and socializing with other dogs.

Below is a picture of our dog in the off-leash part of Pulgas Ridge OSP. Notice that the ground is largely dirt. .

2 Of course not every city will have a 17 acre open space area to offer dogs and their owners. But the fact that the dogs are pleased wherever they are in such a space should give everyone pause. The dogs don’t care whether they are on a crushed granite surface or some other surface … with a few caveats.

Please see the picture below taken in Sunnyvale. Note that on October 5, 2024 the air temperature was 92°F while the surface of the plastic turf was 52°F hotter, at 144°F.

3 Dogs will not walk across a hot surface like that because it will hurt their paws. Dogs do not have shoes to protect their feet. Below are pictures I took at the Reed & Grant dog park in the City of Santa Clara on a different, summer day. Notice that the dogs are not playing, though they are socializing a bit. In fact they’re doing their best to stay off the very hot artificial turf. What is the purpose of having all of this space if it can’t be used?

4 Heat is only one reason to avoid artificial turf, but I believe you’ve heard from many others about many of the other legitimate and concerning reasons.

However I would like to point out that the agenda packet Item #10, Attachment #1 states that Synlawn artificial turf is recycled at a “Recycling Facility in Germany.” I ask you to consider — why Germany? Surely in 8-10 years, when the warranty expires, Synlawn or Verde is not proposing shipping the worn out turf overseas? Though I believe I know a possible reason for having it sent overseas: Synlawn plastic, even if it’s made from Soybeans (note wording further down saying that they also use Nylon fibers, and Nylon -is- petroleum based) can’t be recycled anywhere. It needs to be recycled in a specific type of industrial setting. Generally speaking the recycling will either be down-cycling, meaning its next life will be in a single-use plastic product and after that it will be landfilled, or it will be put through “advanced recycling” which is really a highly polluting mechanism utilizing high heat. Or, and they admit this, they will simply “repurpose” (“donate”) the worn out stuff to another location will it will continue to degrade and shed micro-plastics into the environment.

Again, I ask: Please do the responsible — and less expensive for Los Altos — thing: Tell your staff to put in a crushed-gravel dog park.

Sincerely,
Susan Hinton
Sierra Club Loma Prieta Chapter Member of the
Plastic Pollution Prevention Committee
https://url.avanan.click/v2/r01/___https://www.sierraclub.org/loma-prieta/plastic-pollutionprevention___.YXAzOmxvc2FsdG9zY2E6YTpvOjA5MzYyM2E3MGI1MTA0Yjk1ZmVhYzEyZjYxMjQ3Y2U3Ojc6M2QzZ DoxOGFhOTI4NjlhMDg4MjNhMDE2ZjQ0N2U5MTkzMTRmNzg2YmNhNDQxN2JiYzcwMmI5ZGQzODBhOGMwYTM0 OTRiOnA6VDpO

1 Melissa Thurman
From: MaryJo Lomax <[email protected]>
Sent: Saturday, October 11, 2025 5:19 PM
To: Public Comment
Subject: Agenda Item #10 Dog Park Surfacing Discussion October 14, 2025 To Whom It May Concern:

I am not in favor of Los Altos installing artificial turf at the Hillview Dog Park. Artificial turf is made of layers of synthetic materials, from the blades of “grass” to the infill (“soil”), to the carpet-like backing. Nothing in artificial turf is biodegradable, and all of it leaches microplastics into the environment. In addition, the turf will have to be regularly treated with deodorizers, and I presume rinsed off with a lot of water, which is at odds with the city’s Green Initiative of Water Conservation.

Why would our city leaders want to expose dogs, their owners, and the community to something that doesn’t seem to have an upside and will have to be replaced in about 10 years? Please, I urge you to reject the artificial turf proposal.

Sincerely,
MaryJo Lomax

1 Melissa Thurman
From: [email protected]
Sent: Saturday, October 11, 2025 9:47 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment As longterm residents of Los Altos, we are most concerned about the pending adaptation of new Zoning Code
Amendments.

THIS CANNOT BE ALLOWED TO HAPPEN.

The amendments, as we understand them, completely exclude any parties interested in preserving aspects of historical Los Altos from the process of zoning approval. It appears that these new amendments ignore potentially valuable City historical assets, and, in addition, are conceding to developers rights which they should not be given without citywide consent. The Historical Commission must be consulted on any and all
decisions relating to aspects of our local history.

Citizens of Los Altos must be given the opportunity to preserve our heritage. Once gone, it can never be restored.

These development rights are also potentially damaging to our local environment, which goes against everything Los Altos has

2 stood for in the past. We fail to understand why protections always provided in the past may now be swept away.

We discern an alarming tendency in the present City Council to flagrantly ignore many of the aspects of our City which make it a desirable place to live. Potentially trampling on historical sites to continue development without consultation by local citizens is not democratic, and does not reflect the values for which we have elected you.

Please DO NOT APPROVE the new Historic Preservation
Ordinance without much more input, and revision, from Los Altos residents.

Attachments Field not completed.

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1 Melissa Thurman
From: Pu Li <[email protected]>
Sent: Sunday, October 12, 2025 8:00 AM
To: Public Comment
Subject: Public Comment - Hillivew Dog Park Surface - Mtg Oct 14, 2025 Dear Los Altos City Council Members,
This email is from Pu and Zhiyi Liu, residents at 108 Hillview Ave, who own the property directly across the street from the [Insert Dog Park Name, if known, or "Hillview Avenue Dog Park"].

We are writing to express our strong objection and significant concerns regarding the proposal to replace the existing ground with artificial turf at the dog park.

While we understand the desire for a low-maintenance solution, we believe that artificial turf is the wrong choice for a public amenity, especially a dog park, for several critical reasons:

Environmental Impact: Artificial turf is an unnatural material that contributes to plastic waste and can leach contaminants into the environment. We advocate for a more sustainable, natural solution.

Hygiene and Odor: Unlike natural grass, artificial turf is non-porous and will not properly absorb or break down biological waste. This can create an unsanitary environment and lead to persistent, unpleasant odor issues, which will significantly impact the quality of life for residents living nearby.

Heat and Safety: Artificial turf absorbs and retains heat, creating a dangerously hot surface in warm weather that could burn a dog's paws and make the park unusable during the summer months.

We urge the City Council to reject this proposal and explore alternative, natural, and environmentally responsible options for the dog park surface.

Thank you for considering our perspective as directly impacted neighbors. We look forward to your thoughtful decision on this matter.

Sincerely,
Pu and Zhiyi Liu
4084785827

1 Melissa Thurman
From: [email protected]
Sent: Sunday, October 12, 2025 8:20 AM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Regarding City Council October 14: Item #6 Zoning Code Amendments.

Please remove this item from agenda until it’s reviewed by the Historical Commission. It’s a bad idea and will diminish our community.

Attachments Field not completed.

Name Ellen Jo Baron, Los Altos Square
Email Field not completed.

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1 Melissa Thurman
From: Ashok Srinath <[email protected]>
Sent: Sunday, October 12, 2025 8:59 AM
To: Public Comment
Subject: Input to the City Council on the dog patch
Dear Sir/Madam,
I support the plan and I'm pleased to see that it's coming to fruition.

Sincerely,
Ashok Srinath
From: Hillview Dog Park Preservation Society <[email protected]> Sent: Saturday, October 11, 2025 6:37:48 PM
To: Hillview Dog Park Preservation Society <[email protected]> Subject: Requesting your input to City Council
Bcc: The Hillview Dog Park Preservation Society mailing list Hello,
At long last, we may be nearing a definitive decision on a permanent dog park at Hillview! Please take some time to research the information below, then weigh in on City Council's upcoming discussion on Tuesday, October 14th. Members of the public are invited to participate by attending the meeting at the Los Altos Council Chamber, located at Los Altos City Hall, 1 N. San Antonio Rd, Los Altos, CA, Public comments are accepted in person at the physical meeting location or via email to [email protected] or through the Public Comment forum on the city website. Comments must be received by Tuesday, October 14th at 5 p.m.

Council plans to discuss whether to use synthetic turf or decomposed granite for the dog park play surfaces. See agenda item #10 on the City Staff report here. It’s my understanding that natural grass was removed from consideration because it’s not sturdy enough to withstand the expected all-seasons, high participant usage.

There are pros and cons with both options.

I'll be glad to compile any questions and share them with this bcc list.

Best regards,
Bette Houtchens

1 Melissa Thurman
From: Maria Bautista <[email protected]>
Sent: Sunday, October 12, 2025 11:09 AM
To: Public Comment
Subject: Public Comment: City Council October 14, 2025 Item #10 Dog Park, Choose #2 Attachments: 736E3775-83D7-4A59-94CE-E0ACDB71E03D.png;
2A6BA8AD-726D-40C1-9125-228F12CC8CF5.png
Dear City Council,
Please choose Option #2 Return Hillview Dog Park to the Predesign/Outreach Stage.  A dog park does not belong at Hillview. It’s disruptive and will result in the destruction of valued community space. The Hillview Field hosts large groups for sports and public events like summer concerts. A dog park is not an appropriate adjacent activity.  The Hillview space is too small. A dog park, per the American Kennel Club, requires a minimum of 1 acre for the benefit of dogs and non-dogs. Dogs, especially both large and small, confined to small spaces adjacent to human activity become nervous. Ask local dog owners, especially those within walking distance of Hillview; they won’t use it.  A dog relief area at Hillview is also not compatible with adjacent activities. Information provided on surface material care, cleaning regimen and the ongoing cost to the city to maintain a dog relief area is not comprehensive.
 The City has provided no data indicating a community priority for a dog park at Hillview. There’s no data on pilot program.

Most recent Hillview Community Center plans indicated an improved and landscaped pedestrian corridor/connection between the community center and downtown Los Altos as a priority.
 No Environmental Impact Report or parking study has been conducted as part of the proposed dog park, a new activity that displaces most of the library parking stalls. The cumulative impact of the proposed library courtyard (100+ person capacity) and a dog park has not been determined; the cumulative impact of new land uses is subject to CEQA.  Recent piecemeal project planning at the Civic Center is a wrongful approach to public land use that is resulting in non-congruent projects and a general aesthetic mess.  With no notice, the City removed two Heritage Oak Trees in the dog park location and is required to replace trees in kind and in place unless otherwise determined through a public process  The current plan does not indicate the numbers of heritage and other trees that are subject to removal for this project for public consideration.

2  Los Altos celebrates its open space. Adding artificial turf, artificial shade structures and decorative fencing is a visual atrocity our community center does not need.

The area at Hillview currently designated for a dog park would serve the community better with a few picnic tables under the shade of majestic trees with landscaped surrounds: a simple and flexible place for spectators to gather, and library and other visitors to enjoy the outdoors. See attached images.

Thank you for pausing this plan.

Best,
Maria Bautista

1 Melissa Thurman
From: Cynthia Tham <[email protected]>
Sent: Sunday, October 12, 2025 1:49 PM
To: Public Comment
Subject: NO to the installation of ARTIFICIAL TURF at the Hillview Dog Park I'm against using artificial turf in any public areas. In this occasion, I'd like to voice my opinion against putting artificial turf at the Hillview Dog Park.

The Sierra Club is against artificial turf in public area:

1. Chemical issues
o PFAS (“forever chemicals”) used in turf (for color, flammability, etc.) that can accumulate in environments and potentially in humans.
o Leaching of toxic or semi-toxic materials (heavy metals, chemicals from the infill, etc.).

2. Microplastics and plastic waste
o Turf shedding small plastic particles, which can enter waterways and soils. o Disposal issues — artificial turf is difficult or impossible to recycle in many cases. After its typical lifespan (~8-10 years), it ends up in landfills

3. Heat and “urban heat island” effect
o Artificial surfaces can get very hot — hotter than natural grass or even asphalt under strong sun — making them dangerous/less usable during heat events.

4. Environmental/ecological concerns
o Loss of biodiversity and habitat when turf replaces natural vegetation. o Issues with stormwater runoff, water absorption, groundwater recharge, etc., since artificial turf doesn’t absorb water like soil or grass does.

5. Health and safety concerns
o Possible exposure risks (skin contact, inhalation, etc.) from chemicals in the materials, especially for children.
o Concerns about burns, overheating, especially in hot weather.

6. Lifecycle cost & sustainability
o While artificial turf may appear to save water or maintenance costs in certain contexts, when you account for manufacturing, installation, chemical inputs, replacement, disposal, etc., the environmental and cost “payback” can be poor.

1 Melissa Thurman
From: Anne Landsberger <[email protected]>
Sent: Sunday, October 12, 2025 2:01 PM
To: Public Comment
Subject: Public Comment | Council Meeting October 14, 2025, Item 10 | Dog Park Surfacing Discussion
Dear Councilmembers,
The claim that “modern” synthetic turf is environmentally friendly is a sales pitch, unsupported by scientific evidence or data. Synthetic turf is plastic — plain and simple.

Plastic turf:
- poses potential risks to both dogs and people.
- traps heat so much that even on moderately warm days, my dog won’t go near it. - inevitably ends up in a landfill, notwithstanding green-washing assurances that it is “recyclable”.
- requires frequent cleaning to manage odor and bacteria. (I’ve visited parks with synthetic turf and can tell you, synthetic turf “stinks” — literally and figuratively.) The bottom line is that artificial turf is a step backward for both environmental stewardship and community health. Please remove synthetic turf from consideration for the Hillview dog park.

Thank you for your attention to this matter.

Best,
Anne Landsberger

1 Melissa Thurman
From: [email protected]
Sent: Sunday, October 12, 2025 2:07 PM
To: Public Comment
Subject: Dog Park Objection
I would like register my objection to the Dog Park proposal. I am very concerned about both animal and human exposure to artificial turf.

I request that the city council reject the current proposal and opt for a more environmentally sustainable surface.

I appreciate your consideration.

Susan LaPointe
Sent from my iPhone

1 Melissa Thurman
From: Caroline Rumptz <[email protected]>
Sent: Sunday, October 12, 2025 2:35 PM
To: Public Comment
Subject: No Turf at Dog Park
Council personsMy husband and I both urge you to reject turf as a surface at the proposed dog park at Hillview. We have serious concerns about the environmental impact, the ongoing odor which absolutely will ensue, the exorbitant cost to install and maintain. It is not a good surface for urine and feces.

As a dog owner I would not choose this park as the surface gets incredibly hot and is not a healthy alternative for pets. The plastic pellets get stuck in paws and tracked around my car and my home. Natural surfaces, such as decomposed granite or a grass are far more environmentally prudent choices.

In an ideal world, we would suggest scrapping the entire dog park project. There already is a dog park at Hillview Park. $1 million for a dog park is a waste of tax dollars.

Thank you
Caroline and Eric Rumptz
717 Linden Ave.

Los Altos, CA 94022

1 Melissa Thurman
From: [email protected]
Sent: Sunday, October 12, 2025 3:19 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment I am writing to support the pausing of the current plan for a dog park and ask my City Council to vote in favor of Option #2 Return to Predesign for Agenda Item #10 Dog Park Surfacing.

Here are some of my reasons: I am a North Los Altos resident 1) I still often see dogs off leash at the Hillview baseball field instead of in the dog park
2) The location impacts library use, and community field use and would displace 20+ parking spots in a parking lot that is already very tight on free spots.
3) I am against spending $1M on an artificial dog park - in this time of need, surely that $1M can be better spent for folks in need of services or food. Or even for safer barriers on Almond Road to protect the bike lane / student cyclists around LAHS (MV and Sunnyvale all have such protective barriers in place) 4) I am against removal of additional heritage trees for the $1 million artificial park
5) Is there data from the Temporary Dog Park use, an
environmental impact study and a traffic study?
Attachments Field not completed.

2 Name Field not completed.

Email Field not completed.

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1 Melissa Thurman
From: Angela Dellaporta <[email protected]>
Sent: Sunday, October 12, 2025 3:46 PM
To: Public Comment
Subject: Artificial turf in dog park
Dear Council Members,
I urge you to reject the idea of installing artificial turf in any city properties, including the dog park that you are considering today in Item #10.

Although plastic is toxic to humans, it currently surrounds us in every aspect of our lives. The artificial turf companies claim that it can be recycled, but even if it does actually get recycled (which I am told is not certain), it will just go towards making more plastic items, continuing the spread of small plastic particles that literally enter our bloodstreams and brains. It is also toxic to animals, fish, birds and other wildlife. Is this the legacy you would like to leave?
The new dog park at Boulware Park in Palo Alto has artificial turf. It is watered daily, to combat the dirt and smells left by dogs — so no water is saved. The turf constantly sheds little plastic leaves, which lie strewn around the area. Where do they end up? No doubt in landfill, in the nearby creak, in birds’ nests, in the nearby playground where children will put them in their mouths. Do we want small particles of plastic in any of these places?
Do we want plastic anywhere? Not really.

Is there a better alternative? Of course there is.

Sincerely, Angela Dellaporta

1 Melissa Thurman
From: [email protected]
Sent: Sunday, October 12, 2025 3:53 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Our Dearest Council Members: (I am worried your meeting will go too late and could miss making comments about the
Hillview Dog Park surface consideration.)
My Preference is for a Synthetic Surface.

I live and work in Los Altos and am also a dog owner. I often walk right past Hillview Dog Park with my pup but cannot bring a muddy dog into my office building, so we do not usually stop.

The grass at the current Hillview Dog Park is rarely dry. Areas of the grass that have been disrupted turn into muddy spots and the grass does not regrow.

I do prefer synthetic turf for year-round dog park enjoyment.

With proper sub surface materials and regular maintenance, synthetic surface dog park will be a perfect addition to downtown amenities.

In my opinion, Los Altos needs six (6) more dog parks for the size and constituency of dog owners living and visiting here.

2 There should be no more delays for opening Hillview Dog Park.

Most of my Los Altos dog friends and I go to neighboring cities every day just to find off leash areas to exercise our pups.

There are plenty of other grass and trail areas for dogs on and off leash to offset Hillview dog Park being synthetic surface.

I support a quality synthetic surface installed in Hillview dog park. There is no way to maintain grass long-term with dog usage and our rainy season. The pesticide grass treatments for weeds, grubs, raccoons are not suitable for these areas.

Thank you for your consideration to finalize Hillview Dog Park with installation of synthetic grass. Barbara Doherty
[email protected]
Attachments Field not completed.

Name Barbara Doherty
Email [email protected]
Email not displaying correctly? View it in your browser.

1 Melissa Thurman
From: John Crawford <[email protected]>
Sent: Sunday, October 12, 2025 4:21 PM
To: Public Comment
Subject: Dog Park
Dear Los Altos Government,
Good afternoon.

The thought of artificial turf in a dog park sounds extremely unsanitary, smelly, especially on hot days, and often very hot.

The proposed new location may have problems growing grass, due to too much shade. The beauty of natural grass is that with water, most or all of the urine and feces sinks down into the soil. Also, the grass gets cut which further removes offending dog deposits. In order to even come close to keeping artificial turf sanitary, you will wind up using more water than with real grass.

I believe the end of Hillview Community Center, near Neutra House, could provide a terrific location. My observation is that the dogs are quiet most of the time. The Community Foundation will not complain, and the next house over is a rental house.

The owners of the rental house, who live up in Los Altos Hills, have a large dog themselves.

Also, the present location of the dog park works as well.

You might consider expanding the Library parking lot into the wood chip area and give the Library more parking.

Again, artificial turf in a dog park is disgusting to me.

Sincerely,
John Crawford, Frances Drive, Los Altos
Sent from my iPhone

1 Melissa Thurman
From: Laura Fay <[email protected]>
Sent: Sunday, October 12, 2025 5:51 PM
To: Public Comment
Subject: Re: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Mayor Daley, Vice Mayor Fligor and Councilmembers Lang, Meadows and Weinberg, I wish to add a note to my previous comment.

At the city council meeting on Aug 26, 2025, I made the request to consider decomposed granite as a preferred dog park surface.

I want to add a clarification to that statement, to be crystal clear on that position.

I, and those that supported my message, are not wedded to the idea of decomposed granite.

The proposals for DG were made in response to the feedback "well, what's the alternative to artificial turf?"
Again to be crystal clear, as long as the surface material is not artificial turf, I am sure the staff will find a solution, factoring community feedback.

Please REJECT THE INSTALLATION OF ARTIFICIAL TURF at the Hillview Dog Park Sincerely,
Laura Fay
On Sat, Oct 11, 2025 at 12:02 PM Laura Fay <[email protected]> wrote:

Dear Mayor Daley, Vice Mayor Fligor and Councilmembers Lang, Meadows and Weinberg, I am writing to request that you listen to the community and REJECT THE INSTALLATION OF ARTIFICIAL TURF at the Hillview Dog Park in favor of a more environmentally sustainable surface for the sake of citizen, canine and environmental health. I make this request for the following reasons....
 The 2023 outreach and surveys conducted by Vered Design/City Staff indicated that natural grass was the preferred surface for the dog park by the community outreach efforts (reference council meeting presentation on July 9th. 2024)
 A 2025 Town Crier survey, open for over three weeks, shows a clear preference for natural grass at 61% of respondents, with artificial turf a distant third preference (as of my time of writing, the poll is still open here. Once taken the results are displayed.

2 o
 Conversation with over a dozen dog owners at the current temporary Hillview Dog Park (which is natural grass), revealed that they overwhelmingly prefer a natural surface, and specifically are against artificial turf. Don't just take my word for it. Please visit there and invite the conversation, or send city staff to have the conversation.

Thank you,
Laura Fay
30-year Los Altos resident

1 Melissa Thurman
From: Dan Beyer <[email protected]>
Sent: Sunday, October 12, 2025 6:42 PM
To: Public Comment
Subject: Support for Installation of Artificial Turf at the Dog Park Dear Members of the City Council,
I am writing to express my strong support for the installation of artificial turf at the dog park. Artificial turf would allow residents and their pets to enjoy the park throughout the entire year. In contrast, the natural grass at the current Hillview Dog Park becomes muddy and unusable during the rainy season and remains closed for extended periods after sprinkler use in the summer. As a result, the park is effectively unavailable for many months each year.

In addition to improved accessibility, artificial turf offers important health and safety benefits.

Maintaining natural grass typically involves the use of fertilizers and other chemicals, which can be ingested by dogs that chew on the grass. Artificial turf eliminates this concern, providing a cleaner and safer environment for pets.

From a maintenance and financial perspective, artificial turf is also the more sustainable choice. It is significantly more durable than natural grass, requiring only periodic rinsing to maintain cleanliness and control odor. In contrast, natural grass demands continual repair due to wear from running and digging, as well as damage caused by squirrels and gophers. Over time, the reduced maintenance and repair needs make artificial turf the more cost-effective option.

Lastly, water conservation must remain a guiding principle in our community’s decisions. While recent years have not seen severe drought, we cannot assume that favorable conditions will continue indefinitely. Artificial turf requires only minimal watering for maintenance, whereas natural grass consumes large amounts of water to remain healthy—particularly when exposed to the effects of pet waste.

For these reasons, I respectfully urge the Council to move forward with the installation of artificial turf at the dog park. This improvement will enhance year-round usability, promote safety and cleanliness, reduce maintenance costs, and demonstrate our community’s commitment to sustainability and responsible water use.

Thank you for your consideration.

Dan Beyer

1 Melissa Thurman
From: Sherry Auerbach <[email protected]>
Sent: Sunday, October 12, 2025 7:26 PM
To: Public Comment
Subject: No to the Installation of Artificial Turf at the Hillview Dog Park Dear Councilmembers,
I urge the city council to vote "no" on the installation of artificial turf at the proposed Hillview Dog Park.

The Los Altos Parks & Recreation Department’s proposal to install artificial turf at the new Hillview dog park directly contradicts the city’s environmental goals, especially the Environmental Commission’s plan to prioritize green landscaping and reduce waste. Los Altos should actively consider decomposed granite as a cost-effective, viable alternative for dog parks - a solution that most Bay Area cities have standardized.

While artificial turf vendors tout “new technology,” the environmental and practical downsides remain significant. These include:

Environmental and Practical Concerns: Artificial turf is still made from plastic and rubber— materials that contribute to microplastic pollution, chemical runoff, and high carbon emissions.

It’s energy-intensive to manufacture and almost impossible to recycle, ending up in landfills every few years. Artificial turf also traps heat, contributing to the urban “heat island” effect, especially problematic in Los Altos, which has 263 sunny days per year.

In winter, the low-permeable base beneath artificial turf can exacerbate flooding and harm tree roots. It doesn't absorb pet waste, leading to odors, bacteria, and increased maintenance, including the need for frequent washing—ironically, with water, despite the drought-conscious rationale for its installation.

Cost and Health Risks: Artificial turf is arguably the most expensive surface option due to high installation, maintenance, and replacement costs. It contains hazardous chemicals like lead, phthalates, and PFAS (“forever chemicals”), with growing evidence of long-term health impacts.

Wider Rejection & Better Alternatives: Other Bay Area cities are rejecting artificial turf.

Sunnyvale is conducting a study and using natural alternatives like crushed stone, generally referred to as Decomposed Granite. Millbrae enforces an artificial turf ban. Santa Rosa, San Marino and Carmel-by-the-Sea have avoided or are banning artificial turf altogether. Leading environmental and health groups, including the Sierra Club and the Santa Clara Medical Association, oppose artificial turf use.

Installing artificial turf at the proposed Hillview dog park would be a costly, unsustainable, and unhealthy step that directly undermines Los Altos 2022 Environmental Commission’s Climate Action and their 2025 Work Plan. There is no good reason to install artificial turf when viable, natural alternatives are being successfully deployed by our neighboring cities.

Best regards,
Sherry Auerbach
379 Hawthorne Ave. Los Altos

1 Melissa Thurman
From: Lynn Wilson Roberts <[email protected]>
Sent: Sunday, October 12, 2025 8:47 PM
To: Public Comment
Subject: Arrival turf
Please vote no on artificial turf in Los Altos. It has no redeeming value. It is expensive to maintain and frankly has no redeeming value except expediency to install. I would never take my beloved dogs to a park with that surface.

Lynn
526 van buren st. Los Altos.

Lynn Wilson Roberts
DRE#: 01814885
578 University Ave.Palo Alto. CA 94301
o: 650.255-6987

1 Melissa Thurman
From: Laura Teksler <[email protected]> Sent: Sunday, October 12, 2025 9:37 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Los Altos City Council Members,
The GreenTown Los Altos board is writing to share our opposition to the installation of artificial turf at the Hillview dog park, as well as other public spaces in the city.

Artificial turf (AT) presents several environmental and health concerns to Los Altos residents in addition to being less pleasant and sanitary for those using the turf surface. While there are many factors to consider in selecting the appropriate surface for a dog park (or other use), we would like to address those we feel most important from a human (and pet) and environmental health standpoint.  Environmental & Human Toxicity: While the products under consideration tout the use of plantbased material and claim to avoid highly problematic rubber crumb infill, they still contain significant amounts of plastic and other petrochemical materials. While the exact composition of the turf products is not disclosed, petroleum based products contain volatile organic compounds (VOCs) which off-gas and contribute to unhealthy air quality and likely contain other toxic substances such as heavy metals, arsenic, micro-plastics and PFAS (forever chemicals).  Excessive heat: AT has a consistently much hotter surface temperature than other surfaces. While this variance depends on the type of turf and other conditions, the surface temperature of turf is consistently measured on the order of 40+ degrees hotter than natural grass and 20+ degrees hotter than asphalt. Even on a mild 80 degree summer day we would expect the turf to be 120-180 degrees (it is not recommended that dogs walk on surfaces more than around 120 degrees). While the proposed shade structure may help mitigate this effect somewhat, it is unlikely to provide a surface that is consistently cool. Turf also contributes to the urban heat island effect so it heats up the surrounding area.
 Impermeability & chemical runoff: Though the products considered claim better permeability, the hard compacted ground required for installation combined with the turf will likely still lead to runoff, carrying with is all the pollutants mentioned above. This is counter to Goal 6.1 in the CAAP that directs expanding green infrastructure to reduce impermeable surfaces.  Solid waste: AT has to be replaced and verified recycling at end of life is not available which means relying solely on company attestations that they recycle their products at end of life. Installing AT will directly counter Goal 3.1 in the CAAP by INCREASING plastic and building material waste.

All too often new products such as the turf products considered here rely on the absence of conclusive longitudinal studies as cover to claim their products are safe, and perhaps even environmentally preferable. Unfortunately often when the science is conclusive it is too late and the harm is done. The environmental movement therefore relies on the precautionary principle which dictates caution in

2 situations where there is threat of harm. Installation of artificial turf is a clear case of potential for harm to human and environmental health that would be very difficult, if not impossible, to abate once the products are in use.

The GreenTown Board, therefore, implores the City Council to reject the use of artificial turf on cityowned property.

1 Melissa Thurman
From: Karina Nilsen <[email protected]>
Sent: Sunday, October 12, 2025 9:45 PM
To: Public Comment
Cc: Bette Houtchens; Hung Kat. Dog Park. Bentley; Hillview Dog Park Preservation Society Subject: Dog park ground cover. NO ARTIFICIAL TURF
Dear City Council members,
Please vote for an alternative to artificial turf for the dog park. DG is far superior.

Keep Los Altos healthy!
Here’s a design idea: utilize natural landscaping such as around Los Altos Civic Center with a wide curving sidewalk near the fence, with grasses and native plants along the edges.

Please consider ADA seating and a water source.

Thank you for your consideration.

With gratitude,
Karina Nilsen
Those who can make you believe absurdities can make you commit atrocities. — Voltaire

1 Melissa Thurman
From: carol little <[email protected]>
Sent: Sunday, October 12, 2025 11:20 PM
To: Public Comment
Subject: Item 10
October 12, 2025
Dear City Council Members,
I currently serve on PARC. However, I am not writing this email as a PARC commissioner, but rather as a resident only.

I am writing regarding Agenda Item 10; Dog Park Surfacing Discussion. Please choose option 2. I am asking that you reject artificial turf as a surface for Hillview dog park, and eventually, McKenzie dog park. I have grave concerns about artificial turf as a surface material for a dog park. A few of my concerns follow.
 It often looks bad after a few years of use.
 It gets extremely hot in the sun, thereby burning dog paws, and creating more heat on our planet. That heat contributes to global warming.
 The cost to install and maintain it is higher than decomposed granite. The cost is not only in dollars but also the cost to that planet.  It harbors bacteria.
 It is very difficult for dog owners and handlers to get all of the feces off of the fake grass.  It contaminates the planet, ocean, and humans with micro plastics.  Dogs are closer to the surface of the fake grass and are more likely to end up with the micro plastics on their paws and ultimately in their mouths when they clean themselves.
 The edges of fake grass blades are known to cut the paws of dogs.  It is made from petroleum based products. We must get away from such products as they are the reason so many wars are fought, as well as what significantly contributes to global warming.  There have been numerous complaints about other dog parks with artificial turf, the odor and the heat issues.  There is no way to recycle the product.
 It requires water, which is a precious resource, to clean the fake grass on a daily basis. We never know when our next major drought will occur.
 If isn’t cleaned regularly, it smells.
 The cost of water is high in many ways, not simply monetary ones.

I realize the choices for the dog park surfaces can seem limited, and in many ways they are, but we can do better than artificial turf. I also recognize that the plans are already completed for the dog park. Please don’t let that stop you. Consider the costs, all of them. As a tax payer, I’d prefer to see my dollars spent on doing the right thing for the planet. Perhaps a variety of surfaces, would be a good option. Decomposed granite, sand, engineered wood chips (not at all the same as regular wood chips). Perhaps even a very small section of real grass in the low impact seating area could provide a nice bit of cool green space for folks, and their pups the relax.

This is an opportunity to do what is best for the planet, please choose option 2. Let’s come up with creative, thinking out of the box solutions.

Thank you for considering my input.

Respectfully,
Teresa Morris

October 12, 2025
Dear City Council Members,
I currently serve on PARC. However, I am not writing this email as a PARC commissioner, but rather as a resident only.

I am writing regarding Agenda Item 10; Dog Park Surfacing Discussion. Please choose option 2.

I am asking that you reject artificial turf as a surface for Hillview dog park, and eventually, McKenzie dog park. I have grave concerns about artificial turf as a surface material for a dog park. A few of my concerns follow.
• It often looks bad after a few years of use.
• It gets extremely hot in the sun, thereby burning dog paws, and creating more heat on our planet. That heat contributes to global warming.
• The cost to install and maintain it is higher than decomposed granite. The cost is not only in dollars but also the cost to that planet.
• It harbors bacteria.
• It is very difficult for dog owners and handlers to get all of the feces off of the fake grass. • It contaminates the planet, ocean, and humans with micro plastics. • Dogs are closer to the surface of the fake grass and are more likely to end up with the micro plastics on their paws and ultimately in their mouths when they clean themselves. • The edges of fake grass blades are known to cut the paws of dogs. • It is made from petroleum based products. We must get away from such products as they are the reason so many wars are fought, as well as what significantly contributes to global warming.
• There have been numerous complaints about other dog parks with artificial turf, the odor and the heat issues.
• There is no way to recycle the product.
• It requires water, which is a precious resource, to clean the fake grass on a daily basis. We never know when our next major drought will occur.
• If isn’t cleaned regularly, it smells.
• The cost of water is high in many ways, not simply monetary ones.

I realize the choices for the dog park surfaces can seem limited, and in many ways they are, but we can do better than artificial turf. I also recognize that the plans are already completed for the dog park. Please don’t let that stop you. Consider the costs, all of them. As a tax payer, I’d prefer to see my dollars spent on doing the right thing for the planet. Perhaps a variety of surfaces, would be a good option. Decomposed granite, sand, engineered wood chips (not at all the same as regular wood chips). Perhaps even a very small section of real grass in the low impact seating area could provide a nice bit of cool green space for folks, and their pups the relax.

This is an opportunity to do what is best for the planet, please choose option 2. Let’s come up with creative, thinking out of the box solutions.

Thank you for considering my input.

Respectfully,
Teresa Morris

1 Melissa Thurman
From: Morrist03@yahoo <[email protected]>
Sent: Monday, October 13, 2025 7:29 AM
To: Public Comment
Subject: Agenda item 6
Dear City Council Members,
I serve on PARC. I am writing this email solely as a resident.

Please reconsider the staff proposed historic changes.

Please continue to have the Historic Commission review all historic projects, whether funded by tax payers, or home owners.

More eyes on a project only make it that much better.

While I am at it, please enact a larger notification area.

Thank you for considering my input.

Teresa Morris

1 Melissa Thurman
From: John Kehoe <[email protected]>
Sent: Monday, October 13, 2025 9:13 AM
To: Public Comment
Subject: Agenda Item #10 – Dog Park Surfacing Discussion - eliminate synthetic turf Dear Mayor Daily, Vice Mayor Fligor and all Councilmembers, Please return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering. Please refrain from supporting the spread of synthetic artificial turf.

A once-living field is prepared for plastic turf by expelling all living organisms, ensuring that it will remain uninhabitable for the foreseeable future.

These plastic fields are heat islands where one did not exist before. And the microplastics that they shed will permeate our environment.

Younger generations will inherit the reality that they will be responsible for the disposal of the old field as, in spite of the industry spokespersons, that stuff is not recycled.

Thank you,
John Kehoe

1 Melissa Thurman
From: joy sheerer <[email protected]>
Sent: Monday, October 13, 2025 10:09 AM
To: Public Comment
Subject: Request to Use Artificial Turf for the New Dog Park Dear City Council,
I would like to strongly encourage the use of artificial turf in the design of the new dog park. Let’s get the design right and create a park that can be enjoyed year-round and last for decades to come.

Artificial turf is widely used in dog parks because it drains efficiently, is antimicrobial, and requires minimal to no chemical maintenance. In contrast, natural grass can quickly turn into a muddy mess during wet weather and often requires fertilizers and pesticides that are unsafe for dogs. Decomposed granite, while lowmaintenance, creates a surface that is uncomfortable and less inviting for both dogs. (Have you ever walked on it barefoot?)
A great example of an effective dog park design can be found at the Village Green Dog Park on San Antonio and El Camino (near Pacific Catch and Mendocino Farms). The artificial turf there drains beautifully, includes built-in sprinklers that operate at night when the park is closed, and provides a clean, safe, and enjoyable play surface.

I’ve spent the past five years visiting Village Green with my dog and have observed that dogs play much more energetically and joyfully on turf. They roll, chase, and wrestle without injury—unlike on harder surfaces such as the concrete areas at Mackenzie Dog Park in Los Altos, where I’ve seen dogs wrestle, fall, and get hurt.

Artificial turf would help ensure our new dog park is safe, durable, and welcoming for both dogs and people.

Thank you for your time and thoughtful consideration.

Sincerely,
Joy Sheerer

1 Melissa Thurman
From: Michael Rochmes <[email protected]>
Sent: Monday, October 13, 2025 10:11 AM
To: Public Comment
Subject: RE: Agenda Item #8 (10/14/25) - Building Code Updates - SUPPORT Attachments: USGBC-CA Letter of Support - Los Altos Building Code Amendments.pdf Dear Mayor Dailey, Vice Mayor Fligor, and Councilmembers, Please find, attached, U.S. Green Building Council California's letter expressing strong support for the Two-Way AC and Electric Readiness local amendments to the 2025 California Building Standards Code (item #8 on the October 14 City Council agenda).

Sincerely,
Michael Rochmes
--
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photo Michael Rochmes
Policy & Advocacy Coordinator, USGBC California
[email protected] 310-954-7034 www.usgbc-ca.org
525 S Hewitt St., Los Angeles, CA, 90013
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October 13, 2025
RE: Agenda Item #8 (10/14/25) - Building Code Updates - SUPPORT Dear Mayor Dailey, Vice Mayor Fligor, and Councilmembers, On behalf of the U.S. Green Building Council California, I write in strong support of the proposed Two-Way AC and Electric Readiness local amendments to the 2025 California Building Standards Code.

USGBC California’s members are designers, engineers, public agency and utility staff, consultants, product manufacturers, and service providers. Our mission is to transform California through the built environment into a more sustainable, resilient, and equitable place for all.

Two-way ACs, commonly known as heat pumps, reduce climate pollution and lower household costs, making this policy a win-win for Los Altos.

Two-Way ACs Reduce Greenhouse Gas Emissions and Air Pollution Two-Way AC policies not only incentivize appliances with twice the functionality of conventional air conditioning units, they also help to offset or completely eliminate the use and future replacement of fossil fuel powered furnaces, because heat pumps can both heat and cool homes. A heat pump with a backup furnace uses about 90% less gas compared to a conventional air conditioner paired with a gas furnace. Greenhouse gas emissions are reduced significantly in the first year, and over the life of the appliance, emissions will continue to decline toward zero as the electric grid is decarbonized.

Beyond just greenhouse gas emission reductions, heat pumps also eliminate harmful indoor and outdoor nitrogen oxides (NOx), which cause smog. This local air pollution worsens many health conditions, such as asthma. Malfunctioning gas furnaces can also cause fatal carbon monoxide poisoning.

Two-Way ACs Save Households Money
The best time for households to switch to a heat pump is when they need to replace their air conditioner. This is because an existing AC system has the necessary electric wiring and capacity in place to allow for a drop-in replacement with a heat pump.

But when air conditioners break down, HVAC contractors often recommend like-for-like replacements, depriving customers of the opportunity to instead install a superior two-way system that would eliminate the need for an expensive furnace replacement down the road.

The California Green Building Council dba USGBC California is a nonprofit 501c(3) charity EIN#75-3041444

While the upfront cost of installing heat pumps is about $2,000 higher than one-way air conditioning, the $1,000 - $2,500 rebate available from Silicon Valley Clean Energy, plus $1,000 - $1,500 state TECH Clean CA rebate can actually make these appliances more affordable for most Los Altos residents than purchasing a new one-way AC. Furthermore, eliminating the need to replace a gas furnace will avoid thousands of dollars in future costs, especially in the Bay Area Air District, where new gas furnaces are set to be phased out in coming years.

In addition to being all electric, heat pumps are also extremely efficient, generally 3 to 4 times more so than conventional gas furnaces. This offsets the so-called “spark gap” between gas and electricity prices, and means that when households make the switch to efficient heat pumps, they are likely to have similar utility costs.

Electric Readiness Requirements Save Households Future Expense Similar to the Two-Way AC reach code, the amendment for Electric Readiness is designed to encourage foresight and protect homeowners from locking in expensive upgrades in the future. The best time to wire an existing home for electrical appliances is when it is being renovated. The proposed reach code only applies when permitted electrical work is performed near existing gas appliances and has thoughtful exemptions to make sure that it is affordable for homeowners.

The Electric Readiness policy also includes forward-thinking requirements that will minimize the need for electrical capacity upgrades, further reducing costs for homeowners and strain on the grid.

As elected officials, you know that home electrification is coming. With these reach codes, you have the opportunity to help Los Altos residents save money by avoiding costly mistakes when replacing their AC or renovating their homes.

Thank you for your consideration.

Sincerely,
Ben Stapleton,
Executive Director
The California Green Building Council dba USGBC California is a nonprofit 501c(3) charity EIN#75-3041444

1 Melissa Thurman
From: Cortney Jansen <[email protected]>
Sent: Monday, October 13, 2025 11:31 AM
To: Public Comment
Subject: Public comment - Item #10 "Dog Park Surfacing Discussion" for Tuesday Oct 14 Council meeting
Dear Los Altos City Council members,
I read with interest that you will be revisiting the decision to install artificial turf at the new Hillview Dog Park at tomorrow (Tuesday, October 14) Council meeting. Hooray! Please do NOT install artificial turf at this dog park (or any other dog parks in the future).

Artificial turf has numerous documented negative health and public safety benefits, which I will not repeat here. It is also not drought-friendly, which is why many water districts, including Valley Water do NOT include the installation of artificial turf in their landscape rebate programs - https://access.valleywater.org/s/article/Landscape-Rebate-Program-articles?language=en_US for more information on why they made this decision.

Specifically for dog parks, artificial turf gets too hot. The American Kennel Club has an article on the risks of heat on pavement and artificial grass, noting: “Pavement, like asphalt or artificial grass, can become incredibly hot and cause discomfort, blisters, and burn a dog’s paw pads,” says Dr. Jerry Klein, DVM, Chief Veterinary Officer for the AKC and an expert in veterinary emergency and critical care. (see https://www.akc.org/expert-advice/health/dog-paws-hot-pavement/) Why would we use a material in a dog park that is known to "cause discomfort, blisters, and burn a dog's paw pads"? Not to mention the smell and sanitary concerns due to dogs urinating and defecating on the plastic grass.

I realize that removing the synthetic turf from the dog park design will require additional time and cost, but it is extremely important to do so. Our dog park must be safe for dogs, otherwise no one will use it.

Please pick a material, such as decomposed granite, that is safe for dogs. Keep the toxic, hot, smelly plastic grass out of our dog parks.

Thank you,
Cortney Jansen
Past (and future) dog owner - right now, I just have cats

1 Melissa Thurman
From: Silja Paymer <[email protected]>
Sent: Monday, October 13, 2025 11:34 AM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Hello,
I am writing as a resident of the Los Altos watershed area to oppose using artificial turf for the dog park.

While I may not live in Los Altos, we all share the water that comes down the hills and enjoy the baylands where all the water flows. Microplastics from artificial turf harm our watersheds. We all lose when someone installs artificial turf.

As a dog owner, I am also opposed. I do not visit any of the dog parks with artificial turf as they are often too hot for my dogs feet, feel dirty as the poop residue just stays on the plastic after pickup, and I worry about the chemical impacts on my dog as they lick their feet often.

Please vote to return to the design phase and choose a plan that is in line with the Los Altos sustainability goals.

Thank you,
Silja Paymer

1 Melissa Thurman
From: Mary Popek <[email protected]>
Sent: Monday, October 13, 2025 1:40 PM
To: Public Comment
Subject: Item #6
Please pull item #6 from the Consent Calendar and send the draft Historical Preservation and Mills Act ordinances to the Historical Commission for review and recommendation.

A concerned citizen and 52 year Los Altos resident,
Mary Popek

1 Melissa Thurman
From: [email protected]
Sent: Monday, October 13, 2025 2:49 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Hello,
I am a resident of Los Altos and a dog owner. I have been an advocate for a permanent dog park in the Hillview area ever since our large group of dog owners and their furry friends were kicked off the Hillview "temporary" dog park on the outfield of the Little League baseball field. I have previously attended Parks Commission meetings, presentations of the expensive plans for the new dog park by the library, a council meeting, and meetings with Manny, who showed us where the new dog park by the Hillview Community Center was to be built. Since the completion of that facility, I have taken my dog to join others and their owners to enjoy the fenced-in area and the shade provided by the tree. Several of us have donated chairs, and they are often full of dog owners. Lately, in the afternoons, the dog park is usually full of happy dogs, and all the chairs are in use. So, this dog park gets enough use, though the grass is not the type traditionally used for dog parks, Manny told us.

I have three recommendations:

1. Keep the current Hillview Dog Park, which is ideal for

2 throwing tennis balls, has shade, and is well-used.

2. Keep the current parking lot as is because it is usually full of cars and is used by theater goers, library patrons, soccer parents, and concert goers in the summer.

3. Choose the option to rethink the plans for the newest proposed dog park by only using the space outside of the parking lot, and using grass appropriate for dog parks, rather than the universally disapproved of artificial turf by dog owners.

The fancier dog park would be less expensive with the reduced size and have fewer maintenance and health issues if it had mostly natural grass. After the large generator building was installed, it became apparent that the area initially specified in the plans for small dogs would be reduced. If the current dog park is retained, dog owners would have the extra space for their dogs to play without incurring the additional expense of separating a small and large dog area at the proposed new dog park or losing valuable parking spaces. There seems to be no practical use for the space now fenced in, other than for a dog park. Please give these suggestions your consideration. I have spoken with other dog owners who hate the idea of artificial turf, having experienced it in the park off San Antonio. I have observed the disapproval of those who use the parking area, as evidenced by those who previously attended meetings to protest the elimination of the parking spaces. I believe my suggestions would be acceptable to both groups. Make your constituents happy and modify the current plans
James L. Sweeney, Ph.D.
owner of Cooper the maltipoo.

By retaining the current park and parking lot, and rethinking the plans for the newer park, especially by using grass instead of the unpopular artificial turf, I believe you would make most of your interested constituents happy, whether they are dog owners or parking lot users. The relatively few complaints about the current park and potential noise, I think, are not worth considering compared to the current popularity of the Hillview Dog Park. The soccer players and concerts make far more noise than our dogs, who are mostly pretty quiet.

Attachments Field not completed.

Name James L. Sweeney
Email [email protected]
Email not displaying correctly? View it in your browser.

1 Melissa Thurman
From: JoAnn Connor <[email protected]>
Sent: Monday, October 13, 2025 5:16 PM
To: Public Comment
Subject: Hillview Dog Park Vote onTurf
October 13, 2025
City of Los Altos
Mayor and City Council Members
1 North San Antonio Road
Los Altos, CA 94022
Honorable Mayor and Council Members,
Please vote NO on Artificial turf for the proposed Hillview Dog Park in Los Altos. The following reasons are why NOT to install AT at the dog park:

Unsanitary, Offensive odor, Requires chemical cleaning Excessive heat, PFAS exposure linked to cancer
Microplastic runoff, High carbon manufacturing
Landfill waste, ’Heat island’ effect
High water consumption (cleaning)
High Cost for installation and maintenance
Real Grass is the best solution. Yes it needs to be mowed. Yes it needs to be watered. Dogs love real grass. People love real grass. A park is to be enjoyed. Artificial Turf stinks with a terrible smell when it gets hot. It’s toxic. Why do people want Artificial Turf when Real Grass is available and is natural. I want to spend my tax dollars on real grass, not Artificial stinky turf.

Sincerely,
JoAnn Connor
50 Oak Street
Los Altos, CA 94022

1 Melissa Thurman
From: Eric Muller <[email protected]>
Sent: Monday, October 13, 2025 5:53 PM
To: Public Comment
Subject: Public Comment - 06/24/2025 City Council Meeting - Not on the agenda Dear Council members,
This comment concerns the new City website.

1. Visiting losaltosca.gov causes my browser to issue requests to the following sites:
doubleclick dot net
facebook dot com
ggpht dot com
google dot com
googleapis dot com
googletagmanager dot com
gstatic dot com
msecnd dot com
youtube dot com
ytimg dot com
An ordinary user is entirely unaware of those requests. Those requests reveal to those sites my IP address, and the fact I visited the Los Altos City website. While this is not uniquely identifying data, it is awfully close, and can be correlated with the other sites I may visit. I consider this a serious intrusion of my privacy, and entirely unacceptable from a government web site (especially in the Silicon Valley).

2. The Privacy Policy entirely fails to alert me that those requests are made. Note that those requests are made automatically, without any action on my part. The third paragraph of the policy does not seem applicable.

3. The requests to those sites result in the downloading of Javascript code, over which the City has no control and cannot possibly vet. This can easily be used by those sites to identify my browser (see the Electronic Frontier Foundation tool at coveryourtracks dot eff dot org)

4. In the Privacy Policy, shouldn't the third paragraph read "Many non-city sites, linked *from* the City Website", rather than "linked *to*"?

5. The "Notifiy Me" feature involves the creation of an account on the site civicplus dot com. I think it is entirely inappropriate to have to create an account on a private third-party web site to use this feature (or any other feature of the City website, for that matter).

6. Furthermore, creating an account involves agreeing to the Terms of Services (19 pages) and the Privacy Policy (13 pages) of civicplus dot com, the Google Privacy Policy (39 pages), and the Google Terms of Services (20 pages). This may sound like an ordinary thing to do to the lawyers on the City Council, but please remember that most of the Los Altos residents are mere mortals.

2 7. I fully appreciate that the City does not have the means of developing a web site from scratch, and that it will naturally rely on third parties (public or private). But I think it is perfectly feasible for the City to build a functional website, without the problems mentioned above.

To make an analogy: when I go to City Hall, I don't have to agree to Terms of Use dictated by the company that built it. If the roof fall on me, I expect the City to take responsibility (and possibly to go after the builder, if appropriate). I also expect that the City has not allowed Facebook to install cameras inside City Hall that point to the front door.

Thanks,
Eric Muller
Los Altos resident
[email protected]
---
Par suite d’un signal d’alarme déclenché par le GIEC, ce train de vie ne prend plus de voyageurs. Merci de prendre les correspondances vers un avenir bas carbone. — Mikhal Bak

1 Melissa Thurman
From: Robert Specker <[email protected]>
Sent: Monday, October 13, 2025 5:56 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear City Council—
Please reject use of artificial turf in the proposed “dog park”.

Also, please eliminate the proposed “dog park” at this, or any other, location in the broader civic center area.

I’d be happy to discuss the reasons for my request by email, or in person, if any of you are interested.

Thank you.

1 Melissa Thurman
From: [email protected]
Sent: Monday, October 13, 2025 6:30 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Los Altos Dog park:

Dear Council members,
As an dog owner we would have preferred grass turf but
understand if this can be challenging to maintain in good shape.

We would be sad if the decision came to be synthetic turf as this is impossible to keep clean and can be unpleasant on warm days.

Thank you for creating a safe and fun place for the dogs of Los Altos!
Attachments Field not completed.

Name Field not completed.

Email Field not completed.

Email not displaying correctly? View it in your browser.

1 Melissa Thurman
From: Cynthia Fan <[email protected]>
Sent: Monday, October 13, 2025 7:45 PM
To: Public Comment
Cc: Public Comment - PARC
Subject: 10/14/25 Council Agenda Item 10 – Council Unanimously Rejects Plastic Dog Park Attachments: council unanimously rejects synthetic turf for dog park.pdf Hi Pete, Neysa, Sally, Jonathan, and Larry,
Join the California communities taking a stand against plastic grass! 씌씇씈씉씊씍씎씏씐씑씒씋누 Just last week, the West Hollywood City Council unanimously rejected a plastic grass dog park! 蔿蕀蕁蕂蕃蕄蕇蕈蕉蕊蕅蕆蕋
Instead, they chose engineered wood fiber — a safe, sustainable alternative.

Striking parallels… Like Los Altos, their council had originally voted over a year ago to install synthetic turf. But the hazards of artificial turf are becoming impossible to ignore, and communities are pushing back en masse.

Let’s follow their lead: No artificial turf in Los Altos, please.

Thank you for using your elected powers to do good for all, Cynthia Fan
See attached news article:
https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/

BY SAM MULICK / OCTOBER 8, 2025
WeHo Council ends Hart Park
turf war
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https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

Hart Park will contain engineered wood fiber in the o!-leash dog playing area. (photo by Sam Mulick) Dogs will now bark, fetch and play on engineered wood fiber – not synthetic turf – at William S. Hart Park in West Hollywood.

On Oct. 6, the West Hollywood City Council unanimously approved engineered wood fiber as the surface material for the designated o!-leash play area at Hart https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

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Park, a popular West Hollywood dog park. The surface material selection precedes larger renovations to make the park compliant with the Americans with Disabilities Act. Redesign plans include leveling the park to bring the o!-leash area closer to De Longpre Avenue and adding a plaza above the o!-leash area. The o!-leash play area – which was recognized as a permanent amenity in the park by the council on Oct. 6 – will be redesigned to include separate big and small dog spaces with a movable fence separating the two areas. The decisions come after recommendations were made by the Hart Park Ad-Hoc Subcommittee, which consisted of Councilmembers Danny Hang and Lauren Meister.

The council had directed city sta! to research di!erent possibilities for surface materials following significant pushback from dog owners after the council originally voted to install synthetic turf in the park in 2018. Urban Design and Architecture Studio Manager Ric Abramson said that engineered wood fiber is clean and safe for dogs, has drainage built into it and meets disability needs for mobility considerations. He added that the material will require regular raking and will likely be replaced several times throughout the year, but the overall long-term maintenance is less than other wood chip materials. Engineered wood fiber is made from 100% wood fiber from the interior wood of trees, not from bark, and does not include recycled materials such as dyes, petroleum products or glues commonly seen in other wood chip products, according to the sta! report. “Sta! was able to identify one other potential system that seems to hit as many of the markers as possible in terms of being organic and safe and readily maintainable. There is no perfect material in this case – there’s pros and cons to https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

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each,” Abramson said. “We have talked to other jurisdictions who seem to be very happy with the material.”
Bob Claster, who has walked his dogs in Hart Park for 20 years, urged the council to reject synthetic turf, which is featured at other dog parks in the city and he said can contain toxic chemicals.
“I’d like to thank the council for finally, after exhaustive evidence was presented and many months of campaigning and protest, acceding to the community’s overwhelming desire not to have artificial turf polluting our park,” he said. “There isn’t such a thing as safe artificial turf, and it smells bad and it’s bad on about 20 di!erent levels.”
However, Claster, and many other park regulars, decried the renovations and criticized the city for not meaningfully involving dog owners in their decisions. “The main thing that bothered all of us was the fact that it was never a collaborative process. It was never ‘Hey, let’s all sit down and see what we can work out. We’ll make you guys happy and make us happy.’ Everything was always adversarial,” Claster said. “It took a lot of bugging them to get them to post their plans at the actual park so that people could see them and comment on them. And by that point, it was already well too late. They had already formulated these plans.

They clearly were going to do what they were going to do, and they didn’t much care about how we felt about it.”
Abramson said, however, that the city has held 18 di!erent meetings to discuss https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

Hart Park and has posted plans and conducted outreach at the park as part of the decision-making process.

Members of the council expressed their support for the redesign. “My colleagues and I moved this item forward so that Hart Park could be ADA accessible, as well as be an incredible space for dog guardians and their pets, neighboring organizations and businesses, and others – with or without dogs – who visited the park to enjoy the relaxing atmosphere,” Meister said. “Community outreach was fairly extensive and covered a broad and diverse range of stakeholders, beginning pre-COVID through to this most recent council meeting.” “I’m really excited about the design of the park,” Hang said, who also pointed out that the city received feedback from small dog owners requesting a separate area from large dogs. Hang also thanked city sta! for bringing samples of the engineered wood fiber to subcommittee meetings to show dog owners the material.

Councilman John Erickson thanked dog owners for their advocacy and acknowledged that many of them felt left out of the process. “I do think the community ultimately does feel left out and as I understand, that was never the intention,” he said. “As we do more infrastructure projects, the more we can get out, the better.”
West Hollywood resident David Yocum, who has walked his dogs at the park since https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

2001, also criticized the city’s proposed design of leveling the park and separating the o!-leash area into two separate areas. The redesigned o!-leash area will feature more space than the current one, but the area designated for large dogs will be smaller than the current o!-leash space, which is only one area. “There was no outreach whatsoever at the park – not one time, except back in 2020. We were deliberately excluded from the entire process,” he said. “The new design has significant issues and problems regarding safety and comfort. We love our dogs, we thought we would be heard. We were not.”
Yocum criticized city management and the council for a process he said was not democratic.
“None of us want this change. It feels disrespectful for people that have gone there for decades, a lot of people two to three times a day, and they had no interest,” he said. “We understand the park better than anybody, and they didn’t even have any interest in getting our thoughts. We could have participated in a positive way. We could have given up stu! if we needed to, but they never just made the decisions for us and didn’t care what we had to say.”
Following the approval, landscape architectural firm Stoss, Inc. will finalize design, engineering and construction documents for the Hart Park renovation.

City sta! will then commence the bidding process for a general contractor before presenting it to the City Council with the goal of awarding a construction contract in mid-2026. If approved, construction would begin shortly thereafter. https://beverlypress.com/2025/10/weho-council-ends-hart-park-turf-war/ 10/13/25, 7:15 PM

1 Melissa Thurman
From: Gunjan Aggarwal <[email protected]>
Sent: Monday, October 13, 2025 8:35 PM
To: Public Comment
Subject: Public Comment - Hillview Dog Park Surface - Mtg Oct 14, 2025 (Please REJECT artificial turf at Hillview dog park)
Hello,
I have been a Los Altos resident and homeowner since 2019. I love the city. There's a lot of good work the city government officials and employees do that goes into making Los Altos a great place to live.

I object to replacing green grass with artificial turf in the dog park. It is a double whammy - one, removing green square footage and second, putting plastic on top.

I request you, Los Altos City council to please REJECT artificial turf at the Hillview dog park, and all city dog parks.

The plastic turfs stink, they need more water, plastic will leech into our soils and that water will go in our city pipes. Granted, it is a small piece of land - I am not saying it is not your decision to make but choose to not expose the city residents to toxins during your watch.

I thank you for the opportunity to give me a voice and I hope you will vote to reject the artificial turf.

Gunjan

1 Melissa Thurman
From: Manya Kaushik <[email protected]>
Sent: Monday, October 13, 2025 8:38 PM
To: Public Comment
Subject: Public Comment - Hillview Dog Park Surface - Mtg Oct 14, 2025 (Please REJECT artificial turf at Hillview dog park)
Hello,
I am a Los Altos resident. I love the city. There's a lot of good work the city government officials and employees do that goes into making Los Altos a great place to live.

I object to replacing green grass with artificial turf in the dog park. It is a double whammy - one, removing green square footage and second, putting plastic on top.

I request you, Los Altos City council to please REJECT artificial turf at the Hillview dog park, and all city dog parks.

The plastic turfs stink, they need more water, plastic will leech into our soils and that water will go in our city pipes. Granted, it is a small piece of land - I am not saying it is not your decision to make but choose to not expose the city residents to toxins during your watch.

I thank you for the opportunity to give me a voice and I hope you will vote to reject the artificial turf.

Manya

1 Melissa Thurman
From: Natasha Bochenski <[email protected]> Sent: Monday, October 13, 2025 8:54 PM
To: Public Comment
Subject: Dog park
Hello,
I am a Los Altos resident. I love the city. There's a lot of good work the city government officials and employees do that goes into making Los Altos a great place to live.

I request you, Los Altos City council to please REJECT artificial turf at the Hillview dog park, and all city dog parks.

I thank you for the opportunity to give me a voice and I hope you will vote to reject the artificial turf.

Sent from my iPhone

1 Melissa Thurman
From: Bonnie Walker <[email protected]>
Sent: Monday, October 13, 2025 10:07 PM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
I strongly urge the City Council to reject artificial turf for the Hillview Dog Park. It’s harmful to humans, pets and the environment. Either keep the natural grass or install decomposed granite but don’t install plastics that are bad for all of us and more costly to our health and the environment.

Thank you for your careful consideration.

Bonnie
Bonnie Burdett Walker
650.255.2714

1 Melissa Thurman
From: Cynthia Fan <[email protected]>
Sent: Tuesday, October 14, 2025 6:52 AM
To: Public Comment
Cc: Public Comment - PARC
Subject: Oct. 14, 2025 Agenda Item 10 — Please Don’t Use Plastic Turf at the Dog Park Attachments: SHPFI to San Diego - Plastic free Dog Park.pdf; State of California — Chemicals in Artificial Turf.pdf
Hi City Council,
I’m writing about the dog park surfacing discussion — October 14, 2025, agenda item 10.

Please don’t put plastic turf at the dog park or anywhere else in Los Altos.

Sally, at the August 26, 2025 City Council meeting, I was surprised to hear you remark that since the council last discussed the dog park, there hasn’t been new information — “just louder voices with the same information.” [1]
To set the record straight: there’s been a lot of new information since July 2024. Here are three important updates.
⸻

1. August 2024 — State Department of Toxic Substances Contol Raises the Alarm About Plastic Grass
The California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) published a report dedicated to the many chemicals in artificial turf [2]. “Based on our evaluation, we are concerned about the potential for adverse impacts from exposure to Candidate Chemicals in artificial turf.”
The report identifies six chemical classes of concern in artificial turf blades and backing — PFAS is just one of them. Even if the Town could buy artificial turf that was legitimately PFASfree, many other hazardous chemicals remain.

DTSC also warned that “recycling of artificial turf may result in microplastic pollution.” They cited studies showing that plastic recycling facilities themselves can be major sources of microplastics — and that workers may inhale these particles (Brown et al., 2023).

Recycling turf is problematic and polluting. Los Altos should avoid installing it in the first place.

2 ⸻

2. January 2025 — Santa Clara County Public Health Department Spoke Out Against Plastic Grass
Our own County’s Public Health Department released a comprehensive literature review on artificial turf [3].

Their expert conclusion:
“Artificial turf poses potential risks to human and environmental health… All operational considerations being equal, the precautionary principle dictates that natural turf is preferred over artificial turf to minimize risk to human and environmental health.” The fact that the County’s public health experts discourage artificial turf should weigh heavily into local decisions.
⸻

3. National Organization has Amassed Volumes of Data Incriminating Plastic Grass Safe Healthy Playing Fields, Inc. (SHPFI) — a nonprofit that educates communities and officials like you about the health and safety risks of plastic grass — has compiled extensive data that most decision-makers haven’t yet seen.

Review the letter SHPFI submitted to the City of San Diego, urging rejection of plastic turf in a proposed dog park [4]. It’s co-signed by eight supporting organizations, and cites multitudes of relevant recent research. For example,
“Exposure to PFAS in dog parks with synthetic turf adds additional risk of cumulative effects… In dogs, endocrine-disrupting chemicals have been associated with higher occurrences of low birth weight, birth defects, developmental delays, certain cancers, renal failure, and newborn pup deaths.”
And yes — unfortunately the image of the dog’s burned paw is real. ⸻
When council approved artificial turf for this dog park in July 2024, this wealth of compelling information on artificial turf concerns had not yet been so well aggregated and publicized so, understandably, the community was not yet as widely aware of the health and environmental risks that come with plastic grass. Public sentiment is rapidly evolving. Nearly 100

3 organization backed the county’s January 2025 proposal to start phasing out the use of plastic grass. https://tinyurl.com/nearly-100-orgs-say-ban-turf On a more personal note, as a native of Flint, Michigan, home to a serious drinking water crisis, I found it especially compelling that the county’s largest drinking water supplier, Santa Clara Valley Water District, supported the proposed county plan to phase out artificial turf (https://tinyurl.com/water-supplier-supports-ban). In my mind, we’d be downright foolish to not do everything within easy reach to comply with the wishes of the source of water that so many of our lives literally depend upon. We’d be crazy to not voluntarily step up in protection of a resource so vital to our long-term health.

Industry might be able to eliminate the PFAS from plastic grass someday, but they’re never going to be able to eliminate the plastic from plastic grass. All that plastic will break down into micro- and nano-plastics eventually, some from the park and plenty more from the site where these plastic carpets get discarded every time they need replacement. Society’s love affair with nonessential plastic is creating an environmental burden we can not keep contained in landfills or clean up. Micro- and nano-plastics are in our air, water, soil, and our bodies. For the benefit of all, it’s imperative that our society do more to reduce nonessential plastic consumption and production.

Now that we collectively know better, we can do better. Los Altos can role model more sustainable practices for the broader community to emulate.

In addition, Los Altos could help educate the broader community like other California agencies do. Take 2 minutes to watch this fun educational video from a California town just a couple hours north of here: https://youtu.be/9Dov_vwTIYI And check out this great info sheet from Santa Clara Valley Water District: https://tinyurl.com/vw-discourages-plastic-grass Put these educational resources on the Town website.

Thank you for considering this wealth of information and using your decision-making power to enable the Town to better role model what it looks like to sustainably support community and environmental health.

Say no to plastic grass.

4 Sincerely,
Cynthia Fan
⸻
References
[1] City of Los Altos – August 26, 2025 City Council Meeting (Video Recording) Public comments and council discussion on the Hillview Dog Park surfacing.

YouTube: https://www.youtube.com/live/oYNY0WQfpuo?si=1Zcl3ndRKqACpgG4&t=8808 [2] California Environmental Protection Agency, Department of Toxic Substances Control(DTSC)
Background Document on Candidate Chemicals in Artificial Turf — August 2024 report identifying six chemical classes of concern in turf materials and warning that turf recycling can release microplastics.

URL: https://tinyurl.com/2024-ca-dept-toxic-substances
[3] Santa Clara County Public Health Department
Artificial Turf: Literature Review of Human and Environmental Health Impacts — January 2025 literature review concluding that artificial turf poses risks to human and environmental health and recommending natural turf as the safer choice.

URL: https://tinyurl.com/2025-01-28-county-pub-health
[4] Safe Healthy Playing Fields, Inc. (SHPFI)
Letter submitted to the City of San Diego regarding a proposed plastic turf dog park, cosigned by eight supporting organizations, highlighting PFAS and health risks to dogs and people.

URL: https://tinyurl.com/shpfi-san-diego-dog-park

To: Mr. Nicholas Ferracone, Senior Planner; [email protected] CC: San Diego City Council members Joe LaCava, Jennifer Campbell, Stephen Whitburn, Henry L.

Foster III, Marni vonWilpert, Kent Lee, Raul Campillo, Vivian Moreno, Sean Elo-Rivera Re: NOE 2024050419 - City of San Diego
Rancho Bernardo Community Park Dog Park and ADA Improvements Will San Diego continue to ignore the science while other cities and counties are moving to ban synthetic turf?
We, the undersigned, urge you to stop contributing to climate change, harm to human, domestic animal, wild and aquatic life, destruction of biodiversity, microplastic pollution and millions of pounds of unrecyclable plastic waste, all at the expense of taxpayers.

California Environmental Quality Act - CEQA
The CEQA Notice of Exemption (NOE) that has been filed with the state for this project is invalid. The use of synthetic turf triggers an exception to the categorical exemption that was claimed in the NOE due to :
● Significant environmental impacts that cannot be mitigated ● Unusual circumstances
● Cumulative effects
Section 15304: Minor Alterations to Land:
“Class 4 consists of minor public or private alterations in the condition of land, water, and/or vegetation which do not involve removal of healthy, mature, scenic trees except for forestry or agricultural purposes. Examples include, but are not limited to:
(a) Grading on land with a slope of less than 10 percent, except that grading shall not be exempt in a waterway, in any wetland, in an officially designated (by federal, state, or local government action) scenic area, or in officially mapped areas of severe geologic hazard such as

an Alquist-Priolo Earthquake Fault Zone or within an official Seismic Hazard Zone, as delineated by the State Geologist.
(b) New gardening or landscaping, including the replacement of existing conventional landscaping with water efficient or fire resistant landscaping. (c) Filling of earth into previously excavated land with material compatible with the natural features of the site;
(d) Minor alterations in land, water, and vegetation on existing officially designated wildlife management areas or fish production facilities which result in improvement of habitat for fish and wildlife resources or greater fish production; (e) Minor temporary use of land having negligible or no permanent effects on the environment, including carnivals, sales of Christmas trees, etc; (f) Minor trenching and backfilling where the surface is restored; (g) Maintenance dredging where the spoil is deposited in a spoil area authorized by all applicable state and federal regulatory agencies;
(h) The creation of bicycle lanes on existing rights-of-way. (i) Fuel management activities within 30 feet of structures to reduce the volume of flammable vegetation, provided that the activities will not result in the taking of endangered, rare, or threatened plant or animal species or significant erosion and sedimentation of surface waters.

This exemption shall apply to fuel management activities within 100 feet of a structure if the public agency having fire protection responsibility for the area has determined that 100 feet of fuel clearance is required due to extra hazardous fire conditions.” The addition of approximately 64,000 square feet of chemical laden plastic synthetic turf is not insignificant.

Synthetic turf is not water efficient, fire resistant, landscaping; does not constitute a minor alteration of the land; does not result in improvement of habitat for fish and wildlife resources or greater fish production; will result in significant and permanent effects on the environment.

SB 676, signed into law in October 2023 and effective 1 January 2024 specifies “drought-tolerant landscaping does not include the installation of synthetic grass or artificial turf.” An analysis of SB676 notes “…emerging research reveals that artificial turf incurs significant environmental problems including microplastic pollution, chemical run-off and lack of recyclability.” Thirty one environmental and health organizations signed on in support of SB676. There was no opposition to the bill. San Diego Water

Synthetic turf requires the addition of flame retardants as found in numerous patents. These fire retardants may fall under the California Safe Drinking Water and Toxic Enforcement Act (Proposition 65) and may additionally be subject to regulation by CA DTSC under PFAS and chemical classes of concern in synthetic turf.
“Palm trees are prohibited, all tree heights are limited and highly flammable trees may not be planted within 50 feet of any structure. Flammable landscaping material such as shredded bark and artificial turf are prohibited within five feet of a structure.

Wood chips and shredded rubber are prohibited anywhere on site.” Malibu Times CalFire excludes synthetic turf and synthetic fertilizers from grant applications. “Ineligible Practices:

The following practices will not be funded by this grant program:” CalFire 2024 Grant Guidelines

Fluids from maintenance equipment can pose a risk to humans and animals and may trigger a fire on synthetic turf.

Installation of synthetic turf will negatively impact groundwater with toxic runoff of PFAS, microplastics, heavy metals and other chemicals of concern. https://river-runner.samlearner.com

Both microplastics, PFAS and other pollutants will impact surface and groundwater as well as lake Hodges and beyond. The Best Management Practices (BMPs) will capture a small portion of the microplastics lost from the blades and backing and virtually none of the chemicals.

Slide deck https://www.youtube.com/watch?v=hoipI2Yj1DA (@19:55) The impact of approximately 64,000 square feet of chemical laden plastic synthetic turf permanently degrades open space.

The dog park and proposed plastic synthetic turf ‘falls within the City's Multi-Habitat Planning Area (MHPA), and will be required to comply with the MHPA Land Use Adjacency Guidelines as specified in Section 1.4.3 of the Multiple Species Conservation Program's (MSCP) Subarea Plan .”
Synthetic turf can reach temperatures in excess of 200oF, baking and compacting the underlying soil, killing living organisms below it and negatively impacting natural filtration of pollutants, cooling, oxygen production and carbon sequestration. Chemicals leach from the plastic leach and allow runoff containing a toxic load of mixed proprietary chemicals, as well as PFAS and heavy metals.

Synthetic turf and microplastics have caused a decrease in bird populations, accumulation of microplastics on flora and fauna, bees, negatively impacts aquatic organisms, wildlife, ocean habitats, and kills soil biome.

The runoff from synthetic turf will negatively impact the City's Multi-Habitat Planning Area (MHPA).

Applicable under CEQA:

Cal. Pub. Res. Code § 21000(g):
“…all agencies of the state government which regulate activities of private individuals, corporations, and public agencies which are found to affect the quality of the environment, shall regulate such activities so that major consideration is given to preventing environmental damage, while providing a decent home and satisfying living environment for every Californian.”
Cal. Pub. Res. Code § 21002:

CEQA mandates public agencies to disclose significant environmental effects of projects through preparation of an Environmental Impact Report (“EIR”). CEQA includes a substantive obligation of public agencies:
“…should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects.”
Thus, CEQA’s purpose is to “…assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” CEQA is intended “…to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Aptos Council v. County of Santa Cruz, 216 Cal. Rptr. 3d 142, 149 (Cal. Ct. App. 6th 2017) (quoting Laurel Heights Improvement Ass’n v. Regents of Uni. of Cali., 47 Cal.3d 376, 390 (Cal.

S.Ct. 1988).

Legislative and Regulatory Schemes:

An awareness of legislative and regulatory schemes is a requirement under Title 14. Natural Resources. Division 6. California Natural Resources Agency, Chapter 3. Guidelines for the Implementation of the California Environmental Quality Act [CEQA], Article 1. General § 15004, Time of Preparation.

CA DTSC - regulation of PFAS as a chemical class at the PPQ (Parts Per Quadrillion) level CA DTSC - Microplastics, added to Priority Chemicals List CA DTSC - PFAS and other chemicals in synthetic turf (pg. 14) CAStatewide Microplastics Strategy - Senate Bill No. 1263, Chapter 609, 2018 CA Coastal Commission - conditioned permit for UCSB Cesar Uyesaka Baseball for natural grass only, due to microplastic pollution concerns. No removal of trees was also conditioned in the permit.

Greenhouse Gas Emissions:

Cal. Code Regs. tit. 14 § 15064.4 (amendments effective 28 Dec 2018):

A good-faith effort, based to the extent possible on scientific and factual date, to describe, to:
(1) Quantify greenhouse gas emissions resulting from a project; and/or (2) Rely on a qualitative analysis or performance based standards

“…public agencies shall not undertake actions concerning the proposed public project that would have a significant adverse effect or limit the choice of alternatives or mitigation measures, before completion of CEQA compliance.” “In determining the significance of a project’s greenhouse gas emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes.” [emphasis added]
Public Resources Code sections 21155.2 and 21159.28,
“environmental documents for certain residential and mixed use projects, and transit priority projects, as defined in section 21155, that are consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in an applicable sustainable communities strategy or alternative planning strategy need not analyze global warming impacts resulting from cars and light duty trucks. A lead agency should consider whether such projects may result in greenhouse gas emissions resulting from other sources, however, consistent with these Guidelines.” State Air Resources Board pursuant to Division 25.5
(commencing with Section 38500) of the Health and Safety Code. “To maximize public health, environmental, and employment benefits, the lead agency shall require measures that will reduce the emissions of greenhouse gas[s]es in the project area and in the neighboring communities of the baseball park. Not less than 50 percent of the greenhouse gas emissions reductions necessary to achieve the requirements of this clause, excluding the greenhouse gas emissions from residential uses of the project, shall be from local, direct greenhouse gas emissions reduction measures that give consideration to criteria air pollutant and toxic air contaminant emissions reductions, including, but not limited to, any of the following:
(I) Project design features or onsite reduction measures, or both design features and onsite reduction measures.
(II) Off-site reduction measures in the neighboring communities.” Senate Bill No. 32 = CHAPTER 249. An act to add Section 38566 to the Health and Safety Code, relating to greenhouse gas[s]es:

SEC. 2. Section 38566 is added to the Health and Safety Code, to read:
38566. “In adopting rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emissions reductions authorized by this division, the state board shall ensure that statewide greenhouse gas emissions are reduced to at least 40 percent below the statewide greenhouse gas emissions limit no later than December 31, 2030.” Synthetic turf off gasses methane and ethylene in ever increasing amounts. Synthetic turf fields create massive toxic heat islands:
● Methane traps 90% more heat than carbon dioxide.

● Methane is 21 times more potent than carbon dioxide.
● Land based plastics produce 2 times more methane and 76 times more ethylene than plastics in waterways and oceans.
● GHG emissions of 527 tons of CO2e per ten year use period per 7881m2 plastic field. ● Heat islands extend beyond the footprint of the field, impacting the surrounding community; are visible from satellites in space.

The Lawrence Berkeley National Laboratory, in research released in Apr 2024, found that the plastic industry releases about four times as many planet-warming chemicals as the airline industry – exclusive of agricultural and food packaging plastics.

Synthetic turf readily becomes much hotter than nearby asphalt, reaching temperatures of 1600F to 1800F (regardless of infill type) and have even reached over 2000F. Excavation of topsoil and compaction of the underlying earth, covering it with layers of plastic, has negative consequences for all living organisms and biodiversity. Synthetic turf does not allow natural water filtration, cooling or carbon sequestration.

Urban heat islands from synthetic turf in North San Diego County, visible from satellite Heat is already a concern at Rancho Bernardo Dog Park. Why make it worse?!

“Choosing synthetic turf is choosing environmental harm.” Dr. Sarah-Jeanne Royer, Scripps Institute of Oceanography Impervious surface:

Synthetic turf is classified as impervious by both the US EPA and the State of California. U.S.

EPA has defined impervious surfaces:
“...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability.” It has further defined impervious surfaces as…[a]ny surface that prevents or significantly impedes the infiltration of water into the underlying soil. This can include but is not limited to: roads, driveways, parking areas and other areas created using non porous material; buildings, rooftops, structures, artificial turf and compacted gravel or soil.”
Compaction, in addition to the impervious plastic surface, result in increased runoff. Despite synthetic turf industry claims, laboratory testing is not the same as reality. Synthetic turf is unable to handle the amount of rain that comes with an atmospheric river or bomb cyclone.

Augmented by pollutants that accumulate on impervious surfaces (i.e. exhaust; aviation fuels), one inch of rainfall results in 27,000 gallons of toxic runoff per acre. A regulation sized soccer field is 80k square feet (1.84 acres). For areas where snow accumulates on synthetic surfaces, the situation is even more dire as one inch of snow can equal up to 13 inches of rain, significantly increasing the toxic runoff and impacting surface and groundwater, and ultimately drinking water.

Potential for erosion:
“As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, runoff is five times that of a forested watershed. Excessive stormwater runoff also increases the potential for flooding.” US EPA Impervious Surface Fact Sheet
Scripps Institute of Oceanography, University of California San Diego reported 46 total atmospheric rivers along the U.S. West Coast, causing disastrous flooding and loss of property and life during the 2022 to 2023 rainy season. With what has now been categorized as a Super El Niño year currently, increasing frequency and severity of atmospheric events overall,

consideration of synthetic turf is antithetical to environmental responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years on average.

Per- and polyfluoroalkyl substances (PFAS):

The Clean Water Act established the National Pollution Discharge Elimination System (NPDES) in 1972. The US EPA works in conjunction with the State Water Resources Control Board (SWRCB), an authorized state permitting authority of the NPDES. Among other pollutants and chemicals of concern, the NPDES program restricts the discharge of PFAS at their sources.

PFAS were first discovered in synthetic turf in 2019 and have been found in every sample and component tested since, including plastic grass blades, backing, shock pads and the two plant based infills tested.

Obtained from public records, PFAS found to date in synthetic turf components and plant based infill include:
● D2-N-EtFOSAA
● D3-EtFOSA
● D9-EtFOSE
● 6:2 FTS
● 6:2 FTSA
● 7:3 FTCA
● 8:2 FTOH
● 12C2-4:2 FTS
● 13C2-6:2 FTS
● 13C2-8:2 FTS
● GenX
● D3-MeFOSA
● D3-N-MeFOSAA
● D7-MeFOSE
● MTP
● PFBA
● PFBS
● PFDA
● PFHpA
● PFHxA
● PFHxS
● PFNA
● PFOA
● PFOS
● PFPeA
● PFPrA
● PFTrDA
● PMPA
● PPF Acid
● PTFE
● PVDF
● R-EVE
Major research on PFAS in synthetic turf by renowned researchers Dr. Graham Peaslee and Dr.

Heather Whitehead is slated to be published in summer of 2024.

Claims by industry to be able to manufacture synthetic turf without PFAS remains completely unsubstantiated and undemonstrated at any level. In the absence of any third-party, independent verification there is no basis for relying on industry claims, particularly given the universal presence of PFAS in all tests to date.

On 5 April, the California Office of Health Hazard Assessment (OEHHA) issued a press release regarding Protective Health Goals (PHGs) for two PFAS chemicals, PFOA and PFOS, which will be used by SWRCB to develop Maximum Contaminant Levels (MCLs) for drinking water across the state.

On 10 April 2024, the US EPA issued Maximum Contaminant Level Goals (MCLG) and Maximum Contaminant Levels (MCLs) for both PFOA and PFOS in drinking water:
● The US EPA set MCLGs for both PFOA and PFOS at zero.
● MCLs were set at 4.0 ppt for PFOA and PFOS, individually. ● MCLGs and MCLs were established for four additional PFAS chemicals: PFNA, PFHxS, PFBS and “GenX” chemicals.
● MCLGs and MCLs were established at 10 ppt. MCLs set a limit of 10 ppt for any mixture of two or more of: PFNA, PFHxS, PFBS, and “GenX” chemicals. ● All of the named PFAS chemicals have been found in synthetic turf.

Multiple studies have confirmed PFAS, heavy metals, polycyclic aromatic hydrocarbons (PAHs), phthalates and Volatile Organic Compounds (VOCs) leach from and/or aerosolize from plastics.

There is mounting evidence of harm to humans, wild and aquatic life and the environment overall from “forever” PFAS chemicals that bioaccumulate in our food chain and our bodies.

Children are exposed to these toxic and carcinogenic synthetic products in utero, in daycare and preschools, from elementary through high school, in parks- often for hours per day, week on week, year on year. Their exposures can continue through college and beyond. Because of younger children’s hand-to-mouth developmental tendencies (ingestion), smaller stature and developmental windows, they are more likely to be exposed to PFAS and other toxic chemicals that leach into air, water and soil from synthetic turf and other plastic products.

PFAS are endocrine disrupting chemicals that can cause multiple reproductive disorders (including a 40% decrease in female fertility; a decrease of 62.3% total sperm count in males); Crohn’s disease; breast, testicular, kidney, prostate and liver cancers. They cross the blood-brain barrier and are related to Autism Spectrum Disorder, Attention Deficit Hyperactivity Disorder, increased deaths from Parkinson’s and Alzheimer’s diseases; immunological effects; increased serum cholesterol; effects on infant birth weights; impaired glucose metabolism, insulin resistance, dyslipidemia and adiposity in children and adolescents; thyroid hormone disruption (including neonatal) and thyroid cancer.

Exposure to PFAS in dog parks with synthetic turf adds additional risk of cumulative effects related to exposure.

With higher metabolisms and shorter life expectancies, dogs have shorter latency periods than humans for development of diseases and cancers. In dogs, endocrine disrupting chemicals have been associated with higher occurrences of low birth weight, birth defects, developmental delays, certain cancers, renal failure and newborn pup deaths.

Irrigation is required to clean synthetic turf. Warranties generally call for synthetic pesticides to control weed growth through and on top of the plastic carpeting. Potable water is required to clean the plastic to avoid the color bleaching that occurs with higher salt and mineral content of reclaimed water. Additionally, cleaning of synthetic turf requires the use of toxic chemicals, which will be added to the toxic run-off that leaches from the plastic to soil, air and water. It is impossible to remove the odor of urine from the plastic.

Hazardous Waste:

Under CEQA, “Hazardous waste is any hazardous material that is discarded, abandoned, or slated to be recycled. Hazardous materials and waste can result in public health hazards if improperly handled, released into the soil or groundwater, or through airborne releases in vapors, fumes, or dust.”
PFAS and other toxic and carcinogenic chemicals from synthetic turf are known to leach into air, water and soil. As the plastic blades and backing break down due to age, friction, UV radiation and other environmental exposures, dust is created and released into the environment, posing significant human, animal and environmental risk.

Microplastic blade loss estimates vary widely, from 139 pounds/year (2023) to 551-661 pounds/year. The International Association for Sports and Leisure Facilities states (27 Aug 2019):
“mechanical wear from high tread loads – as arising during football or rugby – causes tiny particles or blades of artificial grass to break off. This amounts to 250 to 300 kg per year for modern sports pitches.”
Like a sponge placed over a sink drain, even with the best BMPs (Best Management Practices), only a small percentage of the microplastics and virtually none of the PFAS and other toxic chemicals from plastic turf can be captured.

In humans, micro- and nano-plastics have been found in:
● Heart
● Liver and spleen
● Lungs
● Blood
● Placenta (maternal and fetal sides)
● Newborn and adult feces
● Breastmilk
● Brain
● Testes and semen
Twelve different types of microplastics were found in 100% of both canines and human testes in research just released by the University of New Mexico. “…the most prevalent polymer in both human and canine tissue was polyethylene (PE).”
Polyethylene is the most widely used and most frequently discarded plastic. Synthetic turf is most often made from polyethylene. So are plastic bags and straws.

Microplastic synthetic turf blades have been found in Lake Tahoe and the ocean. In 2021, researchers found that synthetic turf fields in Toronto contribute the 2nd highest amount of microplastics to the environment with only litter contributing a higher amount. This makes synthetic turf clearly a major point source of PFAS and microplastic pollution that cannot go unaddressed.

On 13 December, the CA Coastal Commission conditioned a permit for the Cesar Uyesaka Baseball stadium at UC Santa Barbara, requiring NATURAL GRASS, citing microplastic pollution and noting that synthetic turf is not sustainable nor superior to natural grass.

Additional health hazards:

Failure to clean feces (including infectious diarrhea), urine, blood and saliva from synthetic turf can void the warranty.

Bacteria found on synthetic turf from animals include:
● Staphylococcus
● Streptomyces
● Nocardioldes
● Hymenobactia
Other bacteria found on synthetic turf include:
● Williamsia
● Methicillin Resistant Staph
Aureus (MRSA)
● Chryseobacterium
● Rhodococcus
Silica sand, often used in landscape and other applications, has been on CA Proposition 65 list since 1988 as a known respirable carcinogen. In addition to human risk, dogs, lower to the ground and running across the plastic turf would be inhaling this toxic material as well.

Cumulative impacts under CEQA
● Synthetic turf will off-gass large amounts of greenhouse gasses ● Synthetic turf contributes to climate change, which has negative impacts on wild and aquatic life
● Synthetic turf will “provide substantial additional sources of polluted runoff” ● Synthetic turf and plastics leach PFAS and other toxic chemicals known to bioaccumulate in wild and aquatic and plant life; negatively impacts the food chain ● Synthetic turf will “cause substantial adverse effects on human beings, either directly or indirectly” via:
** Toxic and carcinogenic chemicals known to be bioaccessible and bioaccumulative ** Heat impacts: Heat islands/Heat illness/heat stroke/death ** Increased utility costs for cooling; greater impact on social justice communities where air conditioning is less likely
** Mental health impacts due to loss of green space
** Increased injuries compared to natural grass
** Thermal and friction burns
** Concussions

***Many of these impacts also apply to dogs, wild and aquatic life ● Not recyclable - 32,000 pounds of plastic waste (the weight of 64,000 sq ft of plastic turf) to be landfilled or inappropriately discarded every 8 to 10 years on average ● Hazardous waste/Microplastic pollution - synthetic turf blades contribute 15% of macroand mesoplastic pollution to waterways and the ocean. ** Significant point sources of pollution
** Degrade into microplastics, taking approximately 1000 years to fully decompose. ** Increased off gassing of GHGs with greater degradation (increases surface area) ** Continues to leach chemicals; adsorbs bacteria and other chemicals ● The runoff from synthetic turf will negatively impact the City's Multi-Habitat Planning Area (MHPA).

CA Health & Safety Code Section 25249.6
“Required Warning Before Exposure To Chemicals Known to Cause Cancer Or Reproductive Toxicity. No person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning to such individual, except as provided in Section 25249.10.”
In a press release issued 4 March 2024, the CEO of the Center for Environmental Health (CEH) in Oakland, CA stated:
“No one should be inadvertently exposed to toxic chemicals. Our lawns are places in our homes where we should be able to play and relax, safely. They should not be spaces where we worry about exposing ourselves to harm. Touching artificial turf lawns can expose us to PFAS chemicals when transferred from the turf to our hands and then our mouth.”
CEH sent a Notice of Violation under the California Safe Drinking Water and Toxic Enforcement Act (Proposition 65) for Perfluorooctane Sulfonate (PFOS) in synthetic turf sold by Lowes and Home Depot since at least March 2021. Both big box stores had made previous commitments to selling PFAS free carpeting and failed to notify customers of the carcinogenic PFAS chemicals in the products they sold. Synthetic turf is plastic grass carpeting, made by the same manufacturers and often in the same locations as household and commercial carpeting.

San Diego County District Attorney, Summer Stephans and San Diego Deputy City Attorney, Mark Ankcorn, are both in receipt of the CEH notice.

No one should be exposed to the toxic runoff, the heat or off gassing of toxic methane and ethylene, nor the microplastic pollution from their neighbor’s yard, nor at a dog park.

Use of synthetic turf increases the city’s risk of liability for all of the afore mentioned reasons.

CA Department of Toxic Substances Control (DTSC):
“Synthetic turf, the backing and fiber layers are made of similar materials as carpets and rugs, such as polyvinyl chloride, polypropylene, nylon, and polyurethane…It is estimated that by the end of 2020, 750 fields will be replaced each year, with the average field containing

approximately 40,000 pounds of plastic carpet and 400,000 pounds of infill, accounting for over 300 million pounds of waste annually (STC 2017).”
“The use of artificial turf at outdoor facilities is of concern since they are frequently used by sensitive subpopulations, including young children. While air circulation is generally better in an outdoor application, there is also an increased potential for exposure to Candidate Chemicals in turf due to faster material degradation by outdoor elements, such as ultraviolet light, and high-friction athletic use; in addition to increasing the release of chemicals from artificial turf during use, these factors also affect the product’s life and make it necessary to replace it every eight to 10 years (STC 2017).”
DTSC has already brought PFAS in residential and commercial carpets under regulation. They will be holding a public meeting on PFAS and other chemical categories of concern in synthetic turf in the near future.

Viable Alternative:

Grass fields actively sequester carbon dioxide and provide a cooling function that is especially dramatic when compared to the heat generated by synthetic turf. Grass naturally filters toxins, performs important eco-services for the soil beneath, and provides widely dispersed rainwater infiltration allowing absorption and recharging of the water table. Additionally:
● Research suggests that grasses can accumulate and deposit carbon into the soil by approximately one-half ton of carbon per acre per year for 30 to 40 years. ● Net carbon sequestration rates in urban lawns have been estimated at between 200 and 1,800 lbs of carbon per acre per year.
● Organic management and zero emission maintenance equipment mitigate emissions, reduce costs over time, and increase carbon sequestration. ● Electric mowers are available (there are electric and robotic mowers that can cut 2 acres on a single charge for playing fields).
● Drought and desert tolerant varieties of natural grass appropriate for lawns, parks and high use playing fields are available.
● Bermuda hybrids and sea shore papsulum tolerate the nitrogen content of dog urine better than other varieties of natural grass.
● With soil sampling and soil food biome analysis, appropriate drought tolerant seed or sod selection, professionally installed and maintained natural grass can last without replacement for 30 years.
● Organic management becomes increasingly more cost effective over time. ● Removes the risks associated with synthetic pesticide use, which often contain PFAS, putting children and pets at higher risk for:

Humans:
● chronic diseases
● cancers
● diabetes
● reproductive disorders
● neurological diseases
● birth defects
Dogs:
● lymphoma
● mammary cancer
● bladder cancer

PFAS is known to be found in synthetic pesticides used in California.

It should be noted that synthetic turf may not be replaceable with legislation and/or upcoming regulation.

Plastic grass carpet is merely a way to attempt to sweep lack of maintenance of natural grass under the rug. It is not “set it and forget it.” Failure to maintain synthetic turf, whether in dog park or other applications, including costly cleaning with toxic chemicals, and timely repairs can void a warranty almost as quickly as it is installed. Purchase, installation, maintenance, removal, disposal and replacement (if possible in the future) should not be a taxpayer burden - particularly when it poses clear risks to humans, wild and aquatic life and the environment.

California communities taking action:

Millbrae: banned synthetic turf effective 1 January 2024 San Marino: instituted an interim ordinance prior to signing of SB676. Effective through 12 September 2024.

Sunnyvale: committed to undertaking a study relating to the use of synthetic turf in January 2024.

Santa Clara County: staff was directed to bring a draft ordinance to the Board of Supervisors in June 2024, pending receipt and inclusion of a second report from the Santa Clara County Medical Association,
Los Angeles:

Additional commissions and committees are beginning the process of considering this important issue impacting human and environmental health.

The county of San Diego already has well in excess of 14.3 million square feet of plastic synthetic turf installed in parks and schools alone.

Again, we ask you, will San Diego continue to ignore the science while other cities and counties are moving to ban synthetic turf? Will San Diego continue to contribute to climate change, harm to human, domestic animal, wild and aquatic life, destruction of biodiversity, microplastic pollution and millions of pounds of unrecyclable plastic waste all at the expense of taxpayers? Respectfully submitted,
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
Suzanne Hume, Educational Director &
Founder
CleanEarth4Kids.org
https://CleanEarth4Kids.org
Diana Carpinone, President
Non Toxic Communities
https://www.nontoxiccommunities.com
Joe Houde, President
North County Climate Change Alliance
(NCCCA)
https://ncccalliance.org/
Rika Gopinath, Co-Chair
Moms Advocating Sustainability
www.momsadvocatingsustainability.org
Yousef Miller, Executive Director
North County Equity and Justice Coalition
https://www.facebook.com/NorthcountyEJC/
James Wang, Founder
Eco-Sustainability Peeps,
https://www.facebook.com/ESPeeps/
Dr. Ron Askeland, Coleader
San Diegans for Sustainable, Equitable, & Quiet
Equipment in Landscaping
https://sd-sequel.org

Background Document on
Candidate Chemicals in Artificial Turf
August 2024
Prepared by
Department of Toxic Substances Control
Safer Consumer Products Program
California Environmental Protection Agency

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 2

OVERVIEW
The Safer Consumer Products (SCP) Regulations define the process and criteria we use to evaluate consumer products for possible designation as Priority Products. A Priority Product is a consumer product that (1) contains one or more Candidate Chemicals that have the potential to harm people or the environment, and (2) has been formally listed in the California Code of Regulations through rulemaking. We issue a Priority Product Work Plan (Work Plan), which identifies the product categories the SCP Program may evaluate over a three-year period. In addition to the factors outlined in the SCP Regulations, we evaluate these product categories based on the Work Plan’s stated policy goals.

This document summarizes our preliminary findings on Candidate Chemicals in artificial turf, which falls under DTSC’s current Work Plan within the product category of “Building Products and Materials Used in Construction and Renovation.” The release of this document is part of our external engagement process, which helps us decide whether to conduct additional research or potentially list artificial turf containing one or more Candidate Chemicals as Priority Products. Further, this document shares our initial findings on Candidate Chemicals in artificial turf and asks for information to fill data gaps we have identified.

Based on our evaluation, we are concerned about the potential for adverse impacts from exposure to Candidate Chemicals in artificial turf, which is a product frequently used by sensitive subpopulations, including young children.

DEFINITION: Artificial turf is a synthetic surface material engineered to mimic natural grass. It is made of plastic, blade-like fibers woven into a backing.

Common synonyms for artificial turf include artificial grass, synthetic turf, synthetic grass, AstroTurf, artificial lawn, synthetic lawn, nylon grass, polyethylene grass, and polypropylene grass.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 3

INTRODUCTION
Artificial turf is a synthetic surface material engineered to mimic the appearance of natural grass. This product has become an increasingly popular (Jastifer et al. 2019), cost-effective alternative to fields and lawns in California because it does not require irrigation, fertilizer and pesticide application, or mowing (STC 2022). Artificial turf is versatile and can be used for lawns, sports fields, landscaping, interior design, playgrounds, pet parks, and building rooftops (STC 2011; STC 2022). Modern artificial turf fields resemble natural grass in both look and feel (STC 2022). Despite higher upfront installation costs than natural turf fields, artificial turf fields prove cost-effective after approximately three to four years (STC 2022), with estimated lifespans ranging between five and 15 years (Bertling et al. 2021; Sick et al. 2019). Artificial turf fields also provide two to three times as much playing time as natural grass (STC 2011), because natural grass fields require frequent periods of inactivity to remain healthy (Cheng 2014). School districts and other field providers can schedule far more events on the same surface each year due to this increased activity time.

However, the use of artificial turf raises concerns due to its potential to expose humans and the environment to hazardous chemical constituents; these exposures may result in adverse impacts.

Artificial turf was first included in the scope of our 2021-2023 Priority Product Work Plan (under the product category “Building Products and Materials Used in Construction and Renovation”) in response to public comments received during the rulemaking to list carpets and rugs containing perfluoroalkyl or polyfluoroalkyl substances (PFASs) as a Priority Product (DTSC 2021). The comments expressed concern with PFASs and other Candidate Chemicals used in artificial turf, prompting us to evaluate this product.

This document summarizes our results and remaining questions.

PRELIMINARY SCREENING RESULTS
How much artificial turf is used in California?
We are unable to identify state-specific data on the total amount of artificial turf used in California. We are, however, able to estimate its use in California based on national data.

Artificial turf’s overall sales have increased 15% in North America since 2017 (STC 2020), and other measures confirm this upward trend in popularity. For instance, the Agency for Toxic Substances and Disease Registry (ATSDR) estimates that between 12,000 and 13,000 turf fields existed in the United States in 2016 (ATSDR 2020), up from 8,500 in 2014 (Berger 2016). Recent estimates show that there are 16,000 fields and 265 million square feet of artificial turf installed throughout North America (Penta Group 2022). The United States accounts for approximately 90% of this market (STC 2020).

In 2018, there were an estimated 800 to 1,000 artificial turf sports fields in California (Remke 2018) – approximately 10% of all turf fields in the United States (Berger 2016). More recent estimates show

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 4 that approximately 140-150 artificial turf fields were constructed in California in 2021 (CalRecycle 2021). But sports fields only make up a portion of artificial turf installations. The non-sports field segment of the market accounted for roughly one-third of all installed artificial turf projects in North America in 2020 (STC 2020).

The amount of waste artificial turf generates is expected to rise because a growing fraction of turf installations are replacements rather than new fields (Berger 2016). These replacements accounted for an estimated 22% of the 1,200 to 1,300 fields installed in the United States in 2013 and around 50% of the 1,500 fields installed in 2015 (Berger 2016). About 40,000 pounds of turf and 400,000 pounds of infill are used for an average field (STC 2017).

How is artificial turf manufactured and what is it made of? Artificial turf is a simple-looking product made of plastic grass-like blades attached to a backing. Turf Factory (2019) describes the production of artificial turf as using a sewing process called tufting (Turf Factory 2019). First, resin is combined with additives to form a versatile, “taffy-like” mixture. Next, this mixture is extruded and stretched into blade-like fibers that can be woven and spooled just like a natural fiber (Turf Factory 2019). These artificial turf blades, most commonly made of polyethylene (Jastifer et al. 2019), are then woven into a backing, which typically consists of polyester or polypropylene (Kolitzus 2007). This backing is further coated with polyurethane to provide strength and produce a mat similar to carpet (Jastifer et al. 2019; Turf Factory 2019). The blades and backing are the primary components of artificial turf required to cover the surface it is placed upon (Jastifer et al. 2019).

Artificial turf may include additional materials, depending on the intended use. Layers of hidden material underneath the surface aid in drainage and provide padding but are not required (Jastifer et al. 2019). Infill material between the blades – most commonly rubber or silica sand – also provides cushioning (Jastifer et al. 2019; STC 2022).

Figure 1. Artificial turf structure.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 5 The use of infill material most easily distinguishes artificial turf designed for sports from turf used for aesthetics or domestic purposes (Hann et al. 2018). Infill material may help prevent injury during sports played on artificial turf fields but may not be necessary for installations with less cushioning needed, such as residential yards or interior designs (Jastifer et al. 2019). This report does not examine the makeup of infill material but focuses solely on artificial turf itself – the plastic, grass-like blades and the backing they are attached to.

Which Candidate Chemicals are present in artificial turf? The manufacture of the artificial turf blades requires the use of a combination of chemical additives to ensure the integrity of the product throughout its lifespan (BASF 2022a; BASF 2022b; Hahladakis et al. 2018; Nilsson et al. 2008). Information on the exact chemical formulations used to enhance the plastics that make up artificial turf can be limited and inconsistent; however, common additives include the following chemical classes (Table 1):, per- or polyfluoroalkyl substances (PFASs) to reduce product surface defects, ortho-phthalates to improve plastic processing, colorants to produce a desired color, antioxidants to withstand weathering, and stabilizers to prevent degradation from sun exposure (3M 2016; Hansen et al. 2014; Nilsson et al. 2008).

Table 1: Chemical functional classes used as additives in artificial turf blades and backing.

Chemical Functional
Class Function Example Additives
PFASs* Enhance plastic extrusion
and reduce surface defects
(3M 2016)
Vinylidene fluoride-hexafluoropropylene
polymer*
(3M 2016; 3M 2018)
Ortho-phthalates* Aid in plastic processing
(Hansen et al. 2014)
Di(2-ethylhexyl) phthalate (DEHP)*, diisononyl
phthalate (DINP)*
(Plesser and Lund 2004)
Colorants Add color to blades
(BASF 2022a)
Green copper metallic complexes* or yellow
azo compounds
(Nilsson et al. 2008)
Antioxidants Prevent degradation
caused by oxidation
(Nilsson et al. 2008)
Phenols and organic phosphites
(Nilsson et al. 2008)
Light Stabilizers Prevent degradation
caused by light and heat
(BASF 2022b)
Hindered amine light stabilizers (HALS)
(BASF 2022b)
UV Light Stabilizers Prevent degradation
caused by UV light
(Nilsson et al. 2008)
Zinc tinuvins, hindered amine light stabilizers
(HALS)
(BASF 2022b; Nilsson et al. 2008)
*Present on DTSC’s Candidate Chemicals List (DTSC 2023a). Items without an asterisk are broad functional classes of chemicals and may contain compounds o n the Candidate Chemicals List.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 6 PFASs are a class of chemicals present on DTSC’s Candidate Chemicals List (DTSC 2023a). We plan to use our research on PFASs in carpets and rugs and other products in our evaluation of PFASs in artificial turf. The grass-like, plastic blades in artificial turf contain a subtype of PFASs called fluoropolymers (3M 2016; Lauria et al. 2022; Rice 2021). These fluoropolymers enhance the quality and processing of the plastic by preventing surface defects (3M 2016; Tolinski 2015). Additionally, Zuccaro et al. (2023) recently detected several fluorotelomer alcohols (FTOHs), which are known to degrade to more harmful PFASs, in artificial turf blades. However, we do not know why FTOHs would be present in artificial turf fiber and seek information to help understand which PFASs are used in artificial turf manufacturing beside fluoropolymers.

Ortho-phthalates are a class of plasticizers that may be used in artificial turf blades (Plesser and Lund 2004) and are also present on DTSC’s Candidate Chemicals List (DTSC 2023a). Ortho-phthalates identified in artificial turf blades include dibutyl phthalate (DBP), di(2-ethylhexyl) phthalate (DEHP), diisononyl phthalate (DINP), and dimethyl phthalate (DMP) (Plesser and Lund 2004). Plasticizers enhance the processing and quality of products by softening the plastic (Hansen et al. 2014). Orthophthalates provide additional benefits by imparting qualities such as stain, extraction, and abrasion resistance (Hansen et al. 2014). They also reduce plastic processing time, resulting in higher production rates (Hansen et al. 2014).

Ortho-phthalates detected in the blades of artificial turf (Plesser and Lund 2004) may be contaminants originating from rubber infill (ATSDR 2019a). Ortho-phthalates are commonly used in polyvinyl chloride (PVC) products as plasticizers (OEHHA 2017; Harmon and Otter 2018); yet we found no information that PVC is used in artificial turf. The ortho-phthalates in Table 1 were detected in an artificial turf made of polyethylene/polypropylene copolymer, a plastic that generally does not require any plasticizers (Adewale and Olabisi 2016). In contrast, a larger study completed by the Agency for Toxic Substances and Disease Registry (ATSDR) identified the presence of multiple ortho-phthalates in many artificial turf rubber infill samples (ATSDR 2019a). One artificial turf patent lists the ortho-phthalate DEHP as an ingredient (Yu et al. 2021). We seek information to help fill these data gaps concerning the use of ortho-phthalates in artificial turf. Specifically, we are unsure whether manufacturers intentionally add ortho-phthalates as ingredients in artificial turf or whether they are present as contaminants in artificial turf blades.

Artificial turf also contains various other additives with different functions. For example, colorants dye artificial turf to a variety of colors (BASF 2017; Lambert et al. 2008; SGW 2022). Antioxidants and light stabilizers inhibit weathering and natural degradation caused by light and oxygen exposure (Nilsson et al. 2008), thus preventing color fading and increasing field lifetime (BASF 2022a; STC 2022). We seek more information about these additional additives to better understand their specific chemical identities, presence in artificial turf, environmental fate, and potential associated hazard traits.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 7 Infill is a material that fills the space between artificial turf blades to provide cushioning (Jastifer et al. 2019). The most common type of infill is crumb rubber, which is made from recycled automotive tire rubber and contains many chemicals of potential concern (ATSDR 2019a; ATSDR 2019b), including multiple Candidate Chemicals. Other infill materials exist but are not widely used, including elastomer, polymer, sand, and organic materials such as coconut fiber, cork, and ground walnut shells (Jastifer et al. 2019). The Candidate Chemicals present in crumb rubber originate from tires and are not a chemical ingredient intentionally added during the manufacturing of artificial turf components. Additionally, the use of waste tires in California is regulated by the California Department of Resources Recycling and Recovery (CalRecycle 2024). Therefore, we did not evaluate crumb rubber as part of artificial turf.

However, we are separately evaluating the potential adverse impacts and exposures to chemicals along the life cycle of tires.

What are the hazard traits and adverse impacts of Candidate Chemicals present in artificial turf?
PFASs display multiple hazard traits indicated in OEHHA’s Green Chemistry Hazard Traits regulations (California Code of Regulations, title 22, section 69401 et seq.) including toxicological hazard traits, environmental hazard traits, and exposure potential hazard traits. Fluoropolymers possess unique properties that distinguish them from other PFASs (Korzeniowski et al. 2022). Fluoropolymers present in artificial turf are environmentally persistent due to their notable resistance to chemical, biological, physical, and thermal degradation (Henry et al. 2018). Also, fluoropolymers release trifluoromethane (HFC-23) in the manufacturing process, an extremely powerful greenhouse gas whose global warming potential is 12,400 times higher than of CO2 (CARB 2023; Lohmann et al. 2020; U.S. EPA 2016a). In addition, fluoropolymers may release PFAS monomers1 and processing aids2 during manufacturing and from product use (Lohmann et al. 2020). Neither monomers nor processing aids are intended to be present in the final product (Korzeniowski et al. 2022; Lohmann et al. 2020). Alternatives to perfluorooctanoic acid (PFOA) and other PFAS processing aids exist, but the identity of these alternatives is not always clear (Lohmann et al. 2020; Pro-K 2021). Recent tests of artificial turf blades and backing reveal the presence of PFASs other than fluoropolymers (Ecology Center 2019; TRC 2022).

The detected PFASs are short-chain PFASs, but are still of concern along with the entire class of PFASs (DTSC 2023b). It is unknown whether short-chain PFASs are an added ingredient or a byproduct of the manufacturing process (Ecology Center 2019; TRC 2022).

The hazard traits of ortho-phthalates include developmental toxicity, reproductive toxicity, endocrine toxicity, immunotoxicity, and respiratory toxicity (DTSC 2023a). Ortho-phthalates may also display the 1 PFAS monomers are unreacted PFAS building blocks that form the fluoropolymers themselves. 2 Processing aids are additives used in the manufacturing of products to improve the processing and performance of the material.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 8 hazard trait of mobility in environmental media because of their presence in all environmental compartments (Net et al. 2015). For example, members of this chemical class have been detected in river water and sediment, marine water and sediment, soil, air, wastewater treatment sludge, landfill leachate, and even drinking water (Net et al. 2015). Ortho-phthalates are not chemically bound to the plastics to which they are added, which means they can migrate into the environment throughout the product life cycle (i.e., manufacturing, usage, and disposal) (Prasad 2021). Some ortho-phthalates migrate more readily than others, depending on certain physical and chemical properties (Prasad 2021).
3 We currently have limited information about the identity and hazard traits of the colorants, antioxidants, and light stabilizers used in artificial turf.

Who can be exposed to Candidate Chemicals from artificial turf? Artificial turf users (e.g., athletes, children, and people with residential turf installations) may be exposed to the Candidate Chemicals in artificial turf during sport, play, and leisure. Children are particularly sensitive to the adverse effects that can result from exposure to toxic chemicals, due to “windows of vulnerability” that occur during the active stages of growth and development. In addition, children are more sensitive to toxic chemical exposure because of their low bodyweight compared to adults (ATSDR 2012; WHO 2006).

Exposure to Candidate Chemicals from artificial turf may occur via several pathways. Activities on artificial turf may cause contaminated dust and turf particles to be inhaled, microplastics to be ingested, and additives to be absorbed through the skin. For instance, the presence of orthophthalates in dust, indoor air, and outdoor air (He et al. 2020; Langer et al. 2010) suggests that people near the emission source (i.e., the turf field) may inhale contaminated air or ingest contaminated dust.

The California Office of Environmental Health Hazard Assessment (OEHHA) is currently conducting an assessment of potential health impacts associated with exposures to chemicals released from artificial turf and crumb rubber (OEHHA 2015).

Aquatic organisms can be exposed to Candidate Chemicals in artificial turf when microplastics released from the product are carried to the aquatic environment with runoff and are ingested (Bridson et al. 2021; Li 2019). Plants and soil biota near artificial turf may also be impacted by Candidate Chemicals leaching out of microplastics from weathered artificial turf blades or backing (Ding et al. 2022; Li 2019).

For example, artificial turf blades can release (i.e., leach) ortho-phthalates, metals, and organic compounds when exposed to water (Plesser and Lund 2004). Additionally, off-gassing of volatile 3 The environmental fate and transport of individual ortho-phthalates is highly dependent on physical and chemical properties such as the alkyl chain length, which is a characteristic related to molecular size.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 9 chemicals may be another exposure pathway affecting biota near artificial turf fields. Non-polymeric PFASs tend to become widespread once released into the environment due to their persistence and mobility. For instance, PFAS processing aids and monomers have been detected in surface waters, groundwater, wastewater, and drinking water (Lohmann et al. 2020), and various PFASs have been detected in invertebrates, fish, amphibians, reptiles, birds, and mammals (De Silva et al. 2021).

What happens with artificial turf and the chemicals it contains after its useful life?
Artificial turf is most commonly disposed of in landfills after its intended use (Berger 2016). Evidence of artificial turf recycling is minimal (The Intercept 2019), and reuse is more common with artificial turf infill than with the blades and backing (Zandwijk RTS 2022). Landfill disposal is a concern because of the large mass of waste involved. The roughly 40,000 pounds of turf and 400,000 pounds of infill used in a single average field (STC 2017) has the potential to leach or off-gas significant quantities of hazardous compounds over time. Incineration is another potential form of disposal, but it is problematic because the fluoropolymers in artificial turf can form toxic combustion products (e.g., halogenated benzene and naphthalene compounds) (Myers et al. 2014). Also, incineration only accounts for a small portion of overall waste management in the United States (U.S. EPA 2016b).

Different additives in artificial turf may have different long-term environmental fates (Kwon et al. 2017). While the fluoropolymers in artificial turf are not expected to be highly leachable or mobile in the environment (Henry et al. 2018), their eventual release from artificial turf is expected to increase over time due to weather exposure and frequency of turf use (Lohmann et al. 2020). Fluoropolymer particles degrade into microplastics and have the potential for long-distance environmental transport, as shown by the detection of polytetrafluoroethylene (PTFE) in deep-sea arctic sediment (Bergmann et al. 2017).

In contrast to fluoropolymers, research demonstrates that ortho-phthalates do leach from products (Plesser and Lund 2004; Prasad 2021), but they are only expected to be persistent under certain environmental conditions (e.g., cold, nutrient poor, low oxygen environments) (Net et al. 2015).

Does artificial turf generate microplastics?
Our Work Plan priorities give special consideration to the potential for products to release microplastics to the environment during their use and end-of-life stages. Artificial turf blades are expected to release microplastics to the outdoor environment through wear and tear when used for high-abrasion sports (Hann et al. 2018), such as football and soccer. In addition, weathered artificial turf may also release microplastics to the environment. A report based on data from the International Association Football Federation (FIFA) estimated that artificial turf with a roughly standard pile-height of 40 to 65 mm loses about 0.5% to 0.8% of its fiber mass per year due to microplastic weathering

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 10 (Hann et al. 2018). Finally, artificial turf fibers themselves fall within the dimensional guidelines for microplastics defined by the California State Water Resources Control Board (SWRCB 2020).

There is also concern that recycling of artificial turf may result in microplastic pollution. Some companies and recycling facilities have developed processes to recycle the plastic blades, backing, and infill of artificial turf (Re-Match 2022; TenCate Grass 2022); however, implementing this technology in plastic recycling facilities may be problematic. One study found that plastic recycling facilities may be a major source of microplastic pollution in receiving waters, particularly molecules smaller than 10 micrometers (Brown et al. 2023). These findings also suggest that workers at plastic recycling facilities may be exposed to microplastics through inhalation (Brown et al. 2023).

Research in China has demonstrated that microplastics can reach virtually all waterways (Zhang et al. 2018), raising the concern that microplastic release from artificial turf may have far-reaching effects.

The capacity for artificial turf additives to travel with microplastics is expected to be related to the chemical structure of these additives(Kwon et al. 2017). Pollutants that do not mix well with water may attach to plastic fragments and be carried through the aquatic environment (Hirai et al. 2011).

Are there alternatives to the Candidate Chemicals used as additives in artificial turf?
Potential alternatives to the use of PFASs in artificial turf include boron nitride, thermoplastic urethane elastomers, polyethylene terephthalate (PET), and the alteration of engineering processes (Kulikov 2005; Lambert et al. 2008; NETZSCH Analyzing & Testing 2022; Seth 1997).

Alternatives to ortho-phthalates that have demonstrated lower toxicity potential include citratederived plasticizers (Chiellini et al. 2013; ECHA 2005; RSC 2018) and polymeric plasticizers (Cabeza et al. 2017; Chiellini et al. 2013; Kim et al. 2003; Tan et al. 2013). These are typically considered preferable alternatives either because of their better safety profiles or because of a reduction in migration from the product (Chiellini et al. 2013). Migration of ortho-phthalates can also be reduced by applying crosslinking treatments (Jayakrishnan and Sunny 1996) or heparin coatings (Hildenbrand et al. 2005; Karle et al. 1997) to the surface of products, thereby reducing exposure. According to a market report summary by S&P Global, ortho-phthalates account for a smaller share of the plasticizer market than they did a few years ago, in part due to the rapid growth of alternatives such as terephthalate, epoxy, aliphatic, and benzoate compounds (S&P Global 2021).

While it is unknown to what extent these findings apply to California, the Toxics Use Reduction Institute (TURI) conducted an alternatives assessment evaluating three turf types – organic turf, conventional turf, and synthetic turf – and found organically managed natural grass to be safest and most cost effective when considering the full product life cycle (TURI 2018). Organic turf is natural grass that requires no synthetic pesticides or synthetic fertilizers but requires specific practices to

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 11 encourage healthy grass growth and reduce irrigation needs (TURI 2016). Conventional turf often involves the use of irrigation, as well as synthetic fertilizers and/or pesticides, which may either be applied infrequently in small areas or used routinely (TURI 2016). Synthetic turf does not typically require irrigation, though irrigation may be recommended to lower turf surface temperatures (TURI 2018). Synthetic turf may need to be treated with antimicrobial chemicals to reduce the risk from body fluid contamination and staph infections, something soil microbes typically manage in natural grass (Grassroots Environmental Education 2023). In addition, TURI recommends that communities who install synthetic turf require regular testing of the product for organic compounds and metals to help make more informed decisions about the installed components (TURI 2018).

Is the use of artificial turf regulated?
In 2015, Governor Jerry Brown issued an executive order requiring that 50 million square feet of lawns throughout California be replaced with drought-tolerant landscaping (Gatto 2015). In the wake of this directive, numerous bills were enacted to specifically allow for and protect the right to install residential artificial turf (Civil Code 4735; Gatto 2015). Examples include Assembly Bill 1164 of 2015 (ch. 671, stats. 2015), which prohibited municipalities and counties from restricting the use of artificial turf, and Assembly Bill 349 of 2015 (ch. 266, stats. 2015), which enacted the same prohibition for homeowner associations (Civil Code 4735; Gatto 2015; Government Code 53087.7). However, Senate Bill 676 of 2023 (ch. 498, stats. 2023) specifies that the installation of synthetic grass or artificial turf is no longer included in the definition of drought-tolerant landscaping, once again allowing municipalities and counties to restrict the use of the product. Additionally, Assembly Bill 1423 (2023, Schiavo) would have banned artificial turf containing PFASs in California. With the veto of the bill, we will continue to evaluate PFASs in addition to other Candidate Chemicals in artificial turf.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 12

NEXT STEPS
We are asking you to consider and address the questions listed below. Please submit your answers and any other written comments via CalSAFER. The comment period will close on September 30, 2024, at 11:59 p.m. Pacific Standard Time. In addition, we will hold a public virtual workshop on August 27, 2024. Further details about this workshop will be available on our Workshops and Events Webpage.

This workshop and public comment period will focus on PFASs, ortho-phthalates, and other additives in artificial turf blades and backing, with the goal of soliciting information on data gaps, availability and feasibility of alternatives, and life cycle impacts. This will help inform whether additional research is needed that may result in one or more Priority Product listings.

QUESTIONS
General
· Is the following product definition clear and accurate? o Definition: Artificial turf is a synthetic material engineered to mimic natural grass. It is made of plastic, blade-like fibers woven into a backing. · Are there additional chemicals in the blades and backing components not discussed in this document that SCP should evaluate?
· Can you provide information about any ongoing environmental toxicological or exposure studies on artificial turf?
· Are there any Life Cycle Assessments (LCAs) that evaluate artificial turf in California or U.S. environments?
Chemical Additives
· To what extent do artificial turf manufacturers or raw material suppliers have influence over the chemical additives in their products?
· Is there additional information on PFASs being intentionally added during the manufacturing of artificial turf?
· Are side-chain fluorinated polymers or other PFASs besides fluoropolymers intentionally added to artificial turf?
· Is there information on ortho-phthalates being intentionally added during the manufacturing of artificial turf? If so, what types of plastics used in artificial turf are ortho-phthalates typically added to? If not, what are the sources of contamination to artificial turf? · Is there additional information on other additives being intentionally added in the manufacturing of artificial turf?

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 13 Market Research
· Do you know of any organizations that monitor or have information on the number of artificial turf fields in California?
· Do you have any national or California sales data for artificial turf to share? · How many artificial turf fields are in California?
· How many residential artificial turf installations exist in California or the U.S.? · Approximately what percentage of artificial turf used in California or the U.S. is imported? · Approximately what percentage of artificial turf used in California or the U.S. is manufactured in California?
Alternatives Research
· Are there other safer chemical alternatives for Candidate Chemical additives used in artificial turf that were not identified in this document?
· Do you have any information demonstrating the successful or unsuccessful use of alternatives to the artificial turf additives of potential concern discussed in this document? · Do you have any concerns regarding the potential use of the alternatives listed in this document?
Disposal of Artificial Turf
· In what ways, if any, is artificial turf recycled or reused after its initial use? · What feasible end-of-life solutions could be implemented to prevent further plastic pollution from the continued use of artificial turf?

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 14

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Available at: https://www.atsdr.cdc.gov/frap/tire_crumb.html. Accessed 5 Oct 2022.

BASF. (2017). Colorants Portfolio for Sensitive Applications. Pigments for Plastics. Available at:
https://www.basf.com/us/documents/en/general-businesstopics/pigments/industries/plastics/BASF-Colors-and-Effects_Colorants-portfolio-for-sensitiveapplications_Brochure.pdf. Accessed 2 Jun 2022.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 15 BASF. (2022a). Pigments and Plastic Additives in Artificial Grass. Available at:
https://www.basf.com/be/en/media/featured-topics/basf-product-6.html. Accessed 2 Jun 2022.

BASF. (2022b). Hindered Amine Light Stabilizers (HALS). Available at:
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Berger L. (2016). Recycling and Reuse of Crumb Rubber Infill Used in Synthetic Turf Athletic Fields.

Available at: https://www2.calrecycle.ca.gov/Docs/Web/110952. Accessed 18 Aug 2022.

Bergmann M et al. (2017). High quantities of microplastic in Arctic deep-sea sediments from the HAUSGARTEN observatory. Environmental Science & Technology. 51(19):11000–11010. doi:

10.1021/acs.est.7b03331.

Bertling J et al. (2021). Artificial Turf Pitches – System Analysis for Switzerland and Germany.

Fraunhofer Institute for Environmental, Safety, and Energy Technology UMSICHT. Available at:
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Bridson JH et al. (2021). Leaching and extraction of additives from plastic pollution to inform environmental risk: A multidisciplinary review of analytical approaches. Journal of Hazardous Materials. 414:125571. doi: 10.1016/j.jhazmat.2021.125571.

Brown E et al. (2023). The potential for a plastic recycling facility to release microplastic pollution and possible filtration remediation effectiveness. Journal of Hazardous Materials Advances. 10:100309. doi: 10.1016/j.hazadv.2023.100309.

Cabeza L et al. (2017). Improved antitumor activity and reduced toxicity of doxorubicin encapsulated in poly(ε-caprolactone) nanoparticles in lung and breast cancer treatment: An in vitro and in vivo study. European Journal of Pharmaceutical Sciences. 102:24–34. doi:

10.1016/j.ejps.2017.02.026.

CalRecycle. (2021). California Waste Tire Market Report 2021. Available at:
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BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 16 CARB. (2023). IPCC 100-Year GWP Values. California Air Resources Board (CARB). Available at:
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Cheng H. (2014). Environmental and health impacts of artificial turf: A review. Environmental Science & Technology. 48(4):2114–2129. doi: 10.1021/es4044193.

Chiellini F et al. (2013). Perspectives on alternatives to phthalate plasticized poly(vinyl chloride) in medical devices applications. Progress in Polymer Science. 38(7):1067–1088. doi:

10.1016/j.progpolymsci.2013.03.001.

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Ecology Center. (2019). Toxic “Forever Chemicals” Infest Artificial Turf. Available at:
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BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 17 Gatto M. (2015). Assembly Bill (AB) 1164: Water conservation: drought tolerant landscaping. Available at: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201520160AB1164.

Government Code 53087.7. Government Code, section 53087.7. Miscellaneous. Available at:
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Grassroots Environmental Education. (2023). Synthetic Turf. Available at:
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Hahladakis JN et al. (2018). An overview of chemical additives present in plastics: Migration, release, fate and environmental impact during their use, disposal and recycling. Journal of Hazardous Materials. 344:179–199. doi: 10.1016/j.jhazmat.2017.10.014.

Hann S et al. (2018). Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics Emitted by (but not Intentionally Added in) Products. Final Report. Available at:
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Hansen E et al. (2014). Hazardous Substances in Plastics. The Danish Environmental Protection Agency.

Available at: https://www2.mst.dk/Udgiv/publications/2014/12/978-87-93283-31-2.pdf.

He MJ et al. (2020). Phthalate esters in biota, air and water in an agricultural area of western China, with emphasis on bioaccumulation and human exposure. Science of The Total Environment. 698:134264. doi: 10.1016/j.scitotenv.2019.134264.

Henry B et al. (2018). A critical review of the application of polymer of low concern and regulatory criteria to fluoropolymers. Integrated Environmental Assessment and Management. 14(3):316– 334. doi: 10.1002/ieam.4035.

Hildenbrand SL et al. (2005). PVC-plasticizer DEHP in medical products: Do thin coatings really reduce DEHP leaching into blood? Perfusion. 20(6):351–357. doi: 10.1191/0267659105pf836oa.

Hirai H et al. (2011). Organic micropollutants in marine plastics debris from the open ocean and remote and urban beaches. Marine Pollution Bulletin. 62(8):1683–1692. doi:

10.1016/j.marpolbul.2011.06.004.

Jastifer JR et al. (2019). Synthetic turf: history, design, maintenance, and athlete safety. Sports Health. 11(1):84–90. doi: 10.1177/1941738118793378.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 18 Jayakrishnan A and Sunny MC. (1996). Phase transfer catalysed surface modification of plasticized poly(vinyl chloride) in aqueous media to retard plasticizer migration. Polymer. 37(23):5213– 5218. doi: 10.1016/0032-3861(96)00501-0.

Karle VA et al. (1997). Extracorporeal membrane oxygenation exposes infants to the plasticizer, di(2- ethylhexyl)phthalate. Critical Care Medicine. 25(4):696–703.

Kim SY et al. (2003). Toxic characteristics of methoxy poly(ethylene glycol)/poly(ε-caprolactone) nanospheres; in vitro and in vivo studies in the normal mice. Biomaterials. 24(1):55–63. doi:

10.1016/S0142-9612(02)00248-X.

Kolitzus HJ. (2007). Artificial Turf Surfaces for Soccer. The International Association for Sports Surface Science (ISSS). Available at: https://www.issssportsurfacescience.org/downloads/documents/JG8NGAJQEE_Study_KR_6943_english070511. pdf. Accessed 11 May 2022.

Korzeniowski SH et al. (2022). A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers. Integrated Environmental Assessment and Management. ieam.4646. doi: 10.1002/ieam.4646.

Kulikov O. (2005). Novel processing aids for extrusion of polyethylene. Journal of Vinyl and Additive Technology. 11(3):127–131. doi: 10.1002/vnl.20048.

Kwon JH et al. (2017). Microplastics as a vector of hydrophobic contaminants: importance of hydrophobic additives: Hydrophobic organic contaminants from microplastics. Integrated Environmental Assessment and Management. 13:494–499. doi: 10.1002/ieam.1906.

Lambert YJ et al. (2008). Poly[e]thylene Composition for Artificial Turf. https://patents.google.com/patent/EP1833907B1/en. (Belgium Patent No. EP 1 833 907 B1).

European Patent Office. https://patents.google.com/patent/EP1833907B1/en.

Langer S et al. (2010). Phthalate and PAH concentrations in dust collected from Danish homes and daycare centers. Atmospheric Environment. 44(19):2294–2301. doi:

10.1016/j.atmosenv.2010.04.001.

Lauria MZ et al. (2022). Widespread occurrence of non-extractable fluorine in artificial turfs from Stockholm, Sweden. Environmental Science & Technology Letters. 9(8):666–672. doi:

10.1021/acs.estlett.2c00260.

Li R. (2019). Tracking Microplastics from Artificial Football Fields to Stormwater Systems [Stockholm University]. http://www.diva-portal.org/smash/get/diva2:1330304/FULLTEXT02.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 19 Lohmann R et al. (2020). Are fluoropolymers really of low concern for human and environmental health and separate from other PFAS? Environmental Science & Technology. 54:12820–12828. doi: dx.doi.org/10.1021/acs.est.0c03244.

Myers AL et al. (2014). Using mass defect plots as a discovery tool to identify novel fluoropolymer thermal decomposition products. Journal of Mass Spectrometry: JMS. 49(4):291–296. doi:

10.1002/jms.3340.

Net S et al. (2015). Occurrence, fate, behavior and ecotoxicological state of phthalates in different environmental matrices. Environmental Science & Technology. 49(7):4019–4035. doi:

10.1021/es505233b.

NETZSCH Analyzing & Testing. (2022). Melt Fracture. Its Consequences for Polymer Processing, Viscosity Measurement and Flow Simulation. Available at:
https://www.youtube.com/watch?v=ew-FZfndYY4. Accessed 4 Oct 2022.

Nilsson N et al. (2008). Mapping, Emissions and Environmental and Health Assessment of Chemical Substances in Artificial Turf. Available at: https://www2.mst.dk/udgiv/publications/2008/978- 87-7052-866-5/pdf/978-87-7052-867-2.pdf. Accessed 5 May 2022.

OEHHA. (2015). Synthetic Turf Studies. Office of Environmental Health and Hazard Assessment (OEHHA). Available at: https://oehha.ca.gov/risk-assessment/synthetic-turf-studies. Accessed 1 Jul 2024.

Penta Group. (2022). Synthetic Turf and Crumb Rubber Infill Policy Landscapes. CalRecycle Conference 2022. Recycled Rubber Coalition.

Plesser T and Lund O. (2004). Potential Health and Environmental Effects Linked to Artificial Turf Systems. Norwegian Building Research Institute. Available at:
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Prasad B. (2021). Phthalate pollution: Environmental fate and cumulative human exposure index using the multivariate analysis approach. Environmental Science: Processes & Impacts. 23(3):389– 399. doi: 10.1039/D0EM00396D.

Pro-K. (2021). PFAS Restriction Proposal & Request for Exemption of Fluoropolymers. Available at:
https://www.prokunststoff.de/pro_K_210923%20Response%20to%20Registry%20of%20Intention%20by%20the %20fluoropolymer%20user%20industry_GFL.pdf. Accessed 20 Jun 2022.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 20 Re-Match. (2022). Turf Recycling. Available at: https://re-match.com/turf-recycling/. Accessed 12 Oct 2023.

Remke P. (2018). Patrick Remke Shaw Construction. CalRecycle 2018 California Tire Conference.

Rice P. (2021). Memorandum: Updated Information Regarding Manufacturing Process and New Athletic Field. City of Portsmouth, Department of Public Works.

RSC. (2018). Toxicity Review for Acetyl Tri-N-Butyl Citrate (ATBC). University of Cincinnati Risk Science Center (RSC). Available at: https://www.cpsc.gov/s3fspublic/Toxicity%20Review%20of%20ATBC.pdf.

Seth M. (1997). The Role of Surface Energy of Boron Nitride on Gross Melt Fracture Elimination of Polymers. University of British Columbia. Available at: http://hdl.handle.net/2429/37979.

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Sick S et al. (2019). Artificial Turf Fiber with UV Protection Substances. https://patents.google.com/patent/EP3536742A1/en. (Germany Patent No. EP 3 536 742 A1). 18161114.6. European Patent Office. https://patents.google.com/patent/EP3536742A1/en.

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STC. (2011). Synthetic Turf 360 - A Guide for Today’s Synthetic Turf. Synthetic Turf Council (STC).

Available at: https://cdn.ymaws.com/staging-stc.siteym.com/resource/resmgr/guidelines/Synthetic_Turf_360.pdf. Accessed 11 May 2022.

STC. (2017). Guideline to Recycle, Reuse, Repurpose, and Remove Synthetic Turf Systems. Synthetic Turf Council (STC). Available at:
https://www.syntheticturfcouncil.org/store/viewproduct.aspx?id=17587383. Accessed 20 May 2022.

STC. (2020). Synthetic Turf Council (STC) Releases 2020 Synthetic Turf Market Report for North America. Synthetic Turf Council (STC). Available at:
https://www.syntheticturfcouncil.org/news/512350/Synthetic-Turf-Council-STC-Releases-2020- Synthetic-Turf-Market-Report-for-North-America.htm. Accessed 7 Oct 2022.

BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 21 STC. (2022). Frequently Asked Questions. Synthetic Turf Council (STC). Available at:
https://www.syntheticturfcouncil.org/page/FAQs. Accessed 9 May 2022.

SWRCB. (2020). Resolution No. 2020-0021 Adoption of Definition of ‘Microplastics in Drinking Water.’ State Water Resources Control Board (SWRCB). Available at:
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Tan L et al. (2013). Synthesis, characterization, and acute oral toxicity evaluation of pH-sensitive hydrogel based on MPEG, poly(ε -caprolactone), and itaconic acid. BioMed Research International. 2013. doi: 10.1155/2013/239838.

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BACKGROUND DOCUMENT ON CANDIDATE CHEMICALS IN ARTIFICIAL TURF 22 U.S. EPA. (2016a). Understanding Global Warming Potentials. U.S. Environmental Protection Agency (U.S. EPA). Available at: https://www.epa.gov/ghgemissions/understanding-global-warmingpotentials. Accessed 12 Aug 2022.

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Zhang K et al. (2018). Microplastic pollution in China’s inland water systems: A review of findings, methods, characteristics, effects, and management. Science of The Total Environment. 630:1641–1653. doi: 10.1016/j.scitotenv.2018.02.300.

Zuccaro P et al. (2023). Assessing extraction-analysis methodology to detect fluorotelomer alcohols (FTOH), a class of perfluoroalkyl and polyfluoroalkyl substances (PFAS), in artificial turf fibers and crumb rubber infill. Case Studies in Chemical and Environmental Engineering. 7:100280. doi: 10.1016/j.cscee.2022.100280.

1 Melissa Thurman
From: Kristina Pistone <[email protected]> Sent: Tuesday, October 14, 2025 6:03 AM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Oct 14, 2025 Meeting
Dear Council,
I understand tonight you will be discussing using artificial turf at the Hillview dog park, and I’m writing to encourage you to support the option to
Return the Hillview Dog Park to the pre-design/outreach stage and eliminate synthetic turf as an option for ground covering, and further direct staff to complete the proposed McKenzie Dog Park while Hillview Dog Park is proceeding through redesign.

My primary objections to artificial turf are sustainability related-- in a world where 95% of plastics are not recycled because infrastructure, capacity, demand, or even technology doesn't exist, the complicated plastic product that is artificial turf will almost certainly not be recycled at end of life (5-10 years for most, I believe, depending on use). In the meantime, they shed fibers of microplastics and PFAS-like chemicals into the air and water and thus our (and our pets'!) bodies. Even if the manufacturers have played the whack-a-mole and switched away from the currently regulated ones to one with not enough data yet on the potential harms of the new flavor, that's not actually indicative that the risks are smaller.

Also, while I’m admittedly a cat person, I enjoy going out with the dogs of friends and family, and if there’s one thing I’ve seen, it’s how gross their poops can be on any surface, which you only sometimes can choose (in Argentina they would refer to them as the “dulce de leche” variety, ... not firm)— but the great thing about living grass is it grows, gets watered, and all the microbes and critters in the grass soon return the fecal remnants to the ecosystem where it hopefully won't have negative health impacts. With artificial turf it just ... sits there, until maybe it's washed off, but there's nothing to break it down since that's a dead, artificial surface.

You may be interested to know that your neighbor city Sunnyvale is working on a Study Issue about artificial turf, which should lay out the pros and cons very clearly. San Jose also had a recent shorter summary of the issue saying much the same thing, but since I'm on travel at the moment I can't find the link right now.

The other thing I've learned reading into this issue is it's far more difficult to remove AT once it's installed (sunk costs) so I strongly encourage you to not pursue that avenue at present.

Thanks very much for your attention!
Kristina
Kristina Pistone, PhD
she/her/ella

1 Melissa Thurman
From: cat hung <[email protected]>
Sent: Tuesday, October 14, 2025 7:14 AM
To: Public Comment
Cc: [email protected]
Subject: 10/14/25 #10 Dog Park Artificial Turf, -6” Parking Concerns To Los Altos City Council :

I fully support Los Altos City Council’s approval for a much needed dog park, however, at the last July 2024’s meeting, approval was hastily* given for the option that went against a 60% plus majority vote Against artificial turf and for natural grass. This 60+% vote was taken from all 2024 community hearings, workshops and online polling for the proposed Hillview dog park, which is in the most public, centrally located Los Altos community area.

A second most recent 2025 poll from the Los Altos Town Crier also showed a majority 60+% voting for natural grass, and definitely Not for artificial turf.

Seems most reasonable to rectify a "bad** decision."
Artificial turf is just :
1-not sustainable (after ~8-maybe10 years requires replacement, so trashing to a landfill, and never decomposing.)
2-a heat sink with too hot temperatures for dogs (Los Altos resident cannot use their backyard's artificial turf with their 3rd cattle dog, when too hot.) 3-a health risk for dogs and people, besides smelly as it’s difficult to keep high traffic plastic sanitary. (Los Altos resident's golden retriever's allergic reaction to Village Green's artificial turfcleaning.) Cleaning is the most significant issue for artificial turf. In a dog park, multiple dogs love to urinate/pee and need to poop every day. On artificial turf, daily cleaning is needed for proper sanitation, or the feces and remnants dry on the plastic.

Any cleaning chemicals, "enzymatic" no matter how “natural” needs to kill germs-bacteria and viruses. (Even in the rare occasions, when I spray Lysol “kills 99.9% bacteria & viruses” at my home, I won't allow my terrier-dog near and will leave the area for an extended time.) Some dogs will be more sensitive and allergic to cleaning substances and artificial turf materials, especially over a 8-10year period.
*hastily” approved as we had no discussion after the quick presentation of the two options, and the "no taj mahal dog park needed/Rosita happy free dogs" comments. **bad decision including: 1) the short-sighted diesel fueled generator next to the proposed small dog area, and
2) deducting 6" from each parking space to create more spaces, where the 6" is critical for parking large cars/SUVs/vans, for large and oversize people to get out and in their vehicles,

2 pulling out backseat strollers- knee scooters-kids, strapping in toddlers, giving dogs space to jump in or be carried into the backseat. ...See photo of how tight a "legal size" parking space is.

Thank you each for your serious consideration and attention to the future and best quality of life of Los Altos.

Catherine Hung (current dog park user, frequents downtown, former resident, an investor whose mother chose, loved and died here in Los Altos.)

1 Melissa Thurman
From: cat hung <[email protected]>
Sent: Tuesday, October 14, 2025 7:36 AM
To: Public Comment
Cc: [email protected]
Subject: Re: 10/14/25 #10 Dog Park Artificial Turf, -6” Parking Concerns Attachments: IMG_1647.jpeg; IMG_1798.jpeg; IMG_2053.jpeg; IMG_3180.jpeg; IMG_3384.jpeg +pics -parking & all size dogs in dog park
To Los Altos City Council :

I fully support Los Altos City Council’s approval for a much needed dog park, however, at the last July 2024’s meeting, approval was hastily* given for the option that went against a 60% plus majority vote Against artificial turf and for natural grass. This 60+% vote was taken from all 2024 community hearings, workshops and online polling for the proposed Hillview dog park, which is in the most public, centrally located Los Altos community area.

A second most recent 2025 poll from the Los Altos Town Crier also showed a majority 60+% voting for natural grass, and definitely Not for artificial turf.

Seems most reasonable to rectify a "bad** decision."
Artificial turf is just :
1-not sustainable (after ~8-maybe10 years requires replacement, so trashing to a landfill, and never decomposing.)
2-a heat sink with too hot temperatures for dogs (Los Altos resident cannot use their backyard's artificial turf with their 3rd cattle dog, when too hot.) 3-a health risk for dogs and people, besides smelly as it’s difficult to keep high traffic plastic sanitary. (Los Altos resident's golden retriever's allergic reaction to Village Green's artificial turfcleaning.) Cleaning is the most significant issue for artificial turf. In a dog park, multiple dogs love to urinate/pee and need to poop every day. On artificial turf, daily cleaning is needed for proper sanitation, or the feces and remnants dry on the plastic.

Any cleaning chemicals, "enzymatic" no matter how “natural” needs to kill germs-bacteria and viruses. (Even in the rare occasions, when I spray Lysol “kills 99.9% bacteria & viruses” at my home, I won't allow my terrier-dog near and will leave the area for an extended time.) Some dogs will be more sensitive and allergic to cleaning substances and artificial turf materials, especially over a 8-10year period.
*hastily” approved as we had no discussion after the quick presentation of the two options, and the "no taj mahal dog park needed/Rosita happy free dogs" comments. **bad decision including: 1) the short-sighted diesel fueled generator next to the proposed small dog area, and
2) deducting 6" from each parking space to create more spaces, where the 6" is critical for parking large cars/SUVs/vans, for large and oversize people to get out and in their vehicles,

2 pulling out backseat strollers- knee scooters-kids, strapping in toddlers, giving dogs space to jump in or be carried into the backseat. ...See photo of how tight a "legal size" parking space is.

Thank you each for your serious consideration and attention to the future and best quality of life of Los Altos.

Catherine Hung (current dog park user, frequents downtown, former resident, an investor whose mother chose, loved and died here in Los Altos.)

1 Melissa Thurman
From: Peter Fay <[email protected]>
Sent: Tuesday, October 14, 2025 9:44 AM
To: Public Comment
Subject: Dog Park Artificial Turf
Please REJECT ARTIFICIAL TURF as a surface at the Hillview Dog Park, for reasons of foul odor, environmental disaster, human health and canine health.

Thank You,
Peter Fay
Sent from my iPad

1 Melissa Thurman
From: shane fay <[email protected]>
Sent: Tuesday, October 14, 2025 10:16 AM
To: Public Comment
Subject: Public Comment - Agenda Item #10 – Dog Park Surfacing Discussion - Mtg Oct 14, 2025
Dear Mayor Daley, Vice Mayor Fligor and Councilmembers Lang, Meadows and Weinberg, Please listen to the community and REJECT THE INSTALLATION OF ARTIFICIAL TURF at the Hillview Dog Park
I would never bring my dog to any park with artificial turf.

Sincerely,
Shane Fay
--
Shane Fay
LinkedIn Profile
(650)-906-4208 (mobile)

1 Melissa Thurman
From: Alice Mansell <[email protected]>
Sent: Tuesday, October 14, 2025 12:54 PM
To: Public Comment
Subject: Public Comment City Council Meeting 10/14/25 #6 I request Council pull from its consent calendar item #6, the second reading of its proposed new historic ordinances. As I wrote and said in oral comment last month, there are substantial legal procedural flaws in attempting to promulgate these ordinance changes such as failure to follow Statemandated procedures involving the Certified Local Government City's Historical Commission (HC) .

I listened to Council members debate my concerns last month. One stated on the record there was "no vote" done by the
HC. Another said after the last HC meeting he communicated with more than one HC member privately (and/or through an intermediary(s)), all without prior public notice or comment. Thus, he stated he believed there was a consensus or other majority agreement by the HC to recommend the ordinance changes. Was that a violation of the Brown Act serial meetings law? I was present at the most recent publicly noticed HC meeting, a "special" meeting during the late Summer holiday season done at a time when normally the HC never meets. The clerk called there for two different votes by polling the three HC members present. For both votes, the quorum of 3 of 5 Statemandated law required unanimous votes which could not be reached and thus there was, as college debate societies might say, either a "no" vote or a lack of a "yes" vote.

Council can't ignore procedural laws requiring these historic ordinance changes to go through proper procedures. Not even if Council has a supermajority to vote to ignore any HC's advice from public meetings with proper public notice & comment procedures. Doing so adds to a long list of Council and staff actions which have increasingly eroded since 2019 the legal procedural and substantive public protections for virtually every historic resource in this City which now under Item #6 will reduce public input and appeal rights while giving more power to staff such as increased ministerial discretion. This will continue the steady decline of legal protections for our historical resources on both public and City-owned lands.

This is being done at a time when City Hall has had several major plans to change the uses of now public lands which include trees over 50" in diameter and 50+ year old pistache groves:
- Downtown Parking Plazas 7 and 8 with major housing developer(s) "entitlement" contract(s) which once signed will severely limit public review. Zero environmental or historic mitigation discussions to date at any City commission before allowing developers to bid on every square inch of those lands, not even at the Parks commission.
- Downtown Parking Plazas 1 and/or 2
- Contract with a corporation to implement and enforce new downtown parking fees - Public lands cleared of heritage trees with limited to no public input since Fall 2023 for multiple new construction projects at Civic Center from new paved parking places, new fenced patios, and new underground lines to a semi-budgeted police department expansion.

2 I asked Council last month "why the rush" at this particular time to push through these massive historic ordinance changes given its HC commissioners had most recently not voted "yes" on these changes.

Item #6 will eliminate all administrative and civil court public appeal rights but for those living within 300' of bulldozers or construction fences. That will leave less than miniscule public appeal rights for projects on City-owned land.

What next at this rate? Allow only those who own property within 10' of any new building project to get a mailer warning about "special" historic and planning commission meetings? Allow public notice only from posted signage? Or, allow no public notice anywhere until construction fences go up or gravel is installed for new parking spaces as seen from several recent Civic Center projects permitted as piecemeal projects by staff with zero public review beforehand.

Regards,
Alice
Alice Mansell
Los Altos, California

On Sun, Oct 12, 2025 at 1:31 PM Alice Mansell <[email protected]> wrote:

Super note, Maria. l'll get a written public comment filed on time. Will send it to you asap before emailing to Council asap for review & comment. Got flattened again by my novel 20245 liver/bile issue again, mostly stuck with zero energy and zero appetite in bed at home since Tuesday morning but now on mend slowly with new meds, I hope. If humanely possible I will show up in person at Council on Tues. I can likely stand for at least 30 seconds.

Any signs of life from Mills Act folks?
On Sat, Oct 11, 2025 at 9:20 PM PALLA <[email protected]> wrote:

No one in Los Altos wants a dismantling of our historic and environmental protections.

On Tuesday, October 14, City Council plans to adopt a new Historic Preservation Ordinance that has not been reviewed by the Historical Commission as is required by California state law.

The new ordinance contains major changes that will negatively impact our historic and environmental resources.

Please write to City Council requesting they pull Item #6 Adopt Zoning Code Amendments from the Consent Calendar, and send the draft Historical Preservation and Mills Act ordinances to the Historical Commission for review and recommendation.

The proposed ordinances:

3 • Reduce which properties/natural elements qualify to be considered historic or culturally important • Limit who can initiate a historic designation.
• Leave important decisions to Staff discretion only, including demolition • Reduce noticing and appeals for public properties from “any interested party” to those within a 300’ radius only
• Reduce City Council ability to control development mandated by the state • Act in violation of the California Environmental Quality Act (CEQA) • Allow for Joint Commission Meetings, reducing the opportunities for discovery and public input • Treat historic properties like standard projects with no qualified oversight from the Historical Commission
Write to: [email protected]
Subject Line: City Council October 14: Item #6 Zoning Code Amendments -orFill out Public Comment Form:
https://www.losaltosca.gov/FormCenter/City-Clerk-8/Public-Comment-Submission-to-City-Counci66 Again, please urge City Council to pull Item #6 Adopt Zoning Code Amendments from the Consent Calendar, and send the draft Historical Preservation and Mills Act ordinances to the Historical Commission for their review and recommendation.

These ordinances need mindful and qualified consideration.

Together, we can achieve informed, efficient and effective historic and environmental preservation ordinances by following best practices, our own requirements, codes and state law.

Please share. And show your support in person on Tuesday at City Hall @ 7:00pm! Reply with any questions.

1 Melissa Thurman
From: Mike Sodergren <[email protected]>
Sent: Tuesday, October 14, 2025 12:55 PM
To: Public Comment
Cc: Mike Sodergren; Ben Leech
Subject: Public Comment Oct 14 2025 Los Altos City Council Meeting Consent Calendar Item # 6:

Historic Preservation Ordinances - Request to Remove From Consent and Return to Historical Commission Review.

Re: Resubmittal of Historic Preservation Ordinance Public Comment Letter - Request to Remove From Consent and Return to Historical Commission Review.

Dear Los Altos Mayor City Council Members,
On behalf of the Preservation Action Council of San Jose, please accept the resend of our September 30, 2025 public comment letter regarding the rewrite, repeal and adoption of new Historic Preservation Ordinances in the City of Los Altos.

It appears the original letter was not included in the Sept 30, 2025 agenda packet for deliberation or review record. We respectfully ask that it be entered into the record for tonight's consideration and any related Council actions.

We have had a chance to more fully review the proposed ordinances, staff report and their potential impacts, and feel that the original Sept 30 letter aptly presents some of the considerations and advantageous steps the Council may want to consider before adoption and waiving the second reading in the Consent Calendar of tonight's agenda.

Additionally, some areas in these ordinance adoptions and repeals appear confusing and may very well benefit from a formal referral to your Historical Commission for advisory review as the next step. This seems reasonable given that there has been no expression of urgency that I can see in Staff's recommendation relative to a matter of public interest that requires immediate action.

As noted in the letter, as we work with other municipalities in the region, we have seen the benefits of historic preservation when proper review takes place, to avoid making sweeping decisions that impact the community and cede local authority to others. Given recent actions taken at national and state levels, we strongly encourage all municipalities to be very careful when taking actions that might result in the unintended consequence of the loss of local land use decision authority.

2 Once again we are grateful for your consideration. We ask that the Clerk provide a receipt of this letter, its attachment and the public comment letter text below.

Best Regards,

J. Michael Sodergren
President
Preservation Actions Council of San Jose (PAC*SJ)
42A S. First Street
San Jose, CA 95113
408-930-2561
[email protected]
From: Mike Sodergren <[email protected]>
Date: Tue, Sep 30, 2025 at 6:04 PM
Subject: City of Los Altos City Council – Proposed Zoning Code Amendments for Historic Preservation –9-20-25 Agenda Item No. 7.

To: <[email protected]>
Dear Los Altos City Council Members,
I wish that we could join you at your Council Meeting this evening, but perhaps you will read this short note or some else will read it on our behalf.

We share the concerns expressed by the Preservation Action League of Los Altos (PALLA) and strongly recommend that extreme caution be exercised by Los Altos Council Members and City Staff in making amendments to your existing Historic Preservation Ordinance (HPO). I do not know all the issues at play here, but we recommend that you seek to understand what other CLG's are doing before taking any action that might weaken your authority over historic preservation. It is our understanding that the proposed changes to your HPO will reduce protections for public and private properties, while restricting the breadth of criteria for historic designation, while also limiting community engagement,

3 and reducing your Historical Commission’s responsibilities. From the outside looking in, those appear to be very sweeping decisions.

We echo the assertion by others within your City that Historical preservation programs offer cities such as yours the ability to direct development that impacts historical resources, and your City's overall wellbeing. No one can argue that local decision making relative to land use decisions is under increasing pressure by the State, so regardless of what any individual Council Member may feel about specific preservation initiatives, for the greater benefit of the citizens of Los Altos and Santa Clara County, please do not easily cede decision making control over projects that might impact your historical resources. We concur with PALLA's assertion that by weakening the City’s preservation ordinance, the City can't help but reduce its own ability to control development within Los Altos. I would encourage the Council to take a deep look at the authority cities such as Berkeley, Los Angeles, Long Beach, Oakland, Riverside, San Diego, San Francisco, Santa Barbara, Santa Monica, West Hollywood, etc. have maintained for themselves over land use decisions affecting historic assets. Ironically, the only City that seems to have ceded power to the State is Sacramento. Our City(San Jose) is looking at possible changes to its HPO that it believes may be necessary to serve the greater needs of the people BUT without ceding control to the State. I would also encourage the Council and Staff to consider possible legal implications of making a decision of this nature. Our organization works very hard with City electeds, staff and property owners to find common ground. I would encourage everyone involved in this matter to do the same for the benefit of all your citizens.

Please take your time on making a sweeping decision that cedes local authority to others. Your City has an amazing history that we hope you will treasure and protect on behalf of your citizens and those of us who visit your wonderful city.

4 Best Regards,

J. Michael Sodergren
President
Preservation Actions Council of San Jose (PAC*SJ)
42A S. First Street
San Jose, CA 95113
408-930-2561
[email protected]

1 Melissa Thurman
From: Maria Bautista <[email protected]>
Sent: Tuesday, October 14, 2025 1:23 PM
To: Public Comment
Subject: City Council Meeting October 14, 2025: Item #6 Zoning Amendments Dear City Council,
Please pull Item #6 from the Consent Calendar and move to RECONSIDER this matter at a future date.

On September 30, there was clearly Council confusion about the will of the Historical Commission (HC); the HC has yet to approve minutes from their August 18 meeting. Moreover at that time, the HC was not fully seated as is required by our Certified Local Government status.

Also, there was clearly Council confusion about the tenets of the California Mills Act, Office of Historic Preservation Requirements under CLG as well as the Secretary of Interior Standards for Treatment of Historic Properties application.

Please schedule to consider both the Historical Preservation Ordinance and the Mills Act Ordinance in a forum that allows for broader discussion and clarification both for the City Council and the public.

Thank you,
Maria Batuista

1 Melissa Thurman
From: Christine Maralit <[email protected]>
Sent: Tuesday, October 14, 2025 1:37 PM
To: Public Comment
Cc: Mitchell M. Tsai Attorney at Law, P.C.; Grace Holbrook Subject: PALLA - Agenda Item No. 6 Comment Letter for the 10/14/25 City Council Meeting Attachments: 20251014_PALLA_CityCouncil_CL.pdf
Hello,
Please see the attached comment letter our office is submitting for agenda item No. 6, the Proposed Zoning Code Amendments for Historic Preservation.

We would appreciate confirmation of receipt of this email and its attachment.

Thank you,
Christine
--
Christine Maralit, Assistant Office Manager
Mitchell M. Tsai Law Firm - Environmental and Land Use Litigation 139 South Hudson Avenue Suite 200
Pasadena, CA 91101
Phone: (626) 314-3821
Fax: (626) 389-5414
Email: [email protected]
Website: https://www.mitchtsailaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at [email protected] or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk.

P: (626) 314-3821
E: [email protected]
Mitchell M. Tsai
Law Firm
139 S. Hudson Ave. Ste 200
Pasadena, California 91101

VIA E-MAIL
October 14, 2025
Los Altos City Council
Los Altos Council Chambers
1 N. San Antonio Rd
Los Altos, CA
Em: [email protected]
RE: City of Los Altos City Council – Proposed Zoning Code Amendments for Historic Preservation – Agenda Item No. 6.

Dear Honorable Council Members,
On behalf of Preservation Action League of Los Altos (“PALLA”), my Office is submitting these comments on the City of Los Altos’ (“City” or “Lead Agency”) proposed amendments for the Zoning Code Amendments for Historic Preservation and Mills Act, which will be discussed at the City Council Meeting on October 14, 2025.

PALLA expressly reserves the right to supplement these comments at or prior to hearings on the proposed amendment, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res.

Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.

App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

Moreover, PALLA requests that the City provide notice for any and all events or hearings referring or related to the proposed amendments, as issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

I. THE HEARING SHOULD BE REMOVED FROM THE

CONSENT CALENDAR AND RECONSIDERED AT A

FUTURE DATE
The proposed ordinances should be removed from the consent calendar as significant public participation remains outstanding. This is especially relevant considering the late decision to remove all of the previously implemented revisions to the proposed ordinances. As such, a large portion of the public was unable to voice concerns or comments on this decision. Indeed, previously resolved issues with the proposed ordinances are now relevant again. PALLA respectfully requests that the City remove the agenda item from the consent calendar and reconsider the item at a future hearing date to allow for further public input and discussion on the items.

II. THE HEARING SHOULD BE POSTPONED UNTIL THE

OFFICE OF HISTORIC PRESERVATION HAS REVIEWED

AND COMMENTED ON THE PROPOSED ORDINANCES
When the City of Los Altos became a Certified Local Government, they entered into a Certified Local Government Agreement with the California Office of Historic Preservation (“OHP”). Within that agreement, the City is required to provide OHP the opportunity to review and comment on an ordinance change prior to adoption. (See Exhibit C – 2023-2024 Annual Report, p. 1.) The Staff Report has not mentioned any efforts to provide these ordinances to OHP for their review and comment. If the Council were to take action on these ordinances prior to OHP review, the City would be at risk of losing their Certified Local Government (“CLG”) status. The loss of the CLG status would be in direct conflict with the City’s General Plan and stated role and goals of the Historic Commission (i.e., 2024/2025 Work Plan Goal #7 Maintain the City’s Certified Local Government Status), as well as remove a potential funding source for the City through the loss of the grant funding available to CLGs. As any action on these items is in direct conflict with the City’s responsibilities as a CLG, the City Council must postpone the hearing on these ordinances until the OHP has reviewed and commented on the proposals, as outlined in the CLG Agreement.

At the previous hearing, the City dismissed OHP’s need to review the changes by stating that they were told “minor” changes did not need to be reviewed.

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

However, the record must clearly provide documentation to ensure OHP actually considers these changes to be minor. Until OHP’s position has been clearly established, the City should not take further action on the ordinances.

III. THE HEARING SHOULD BE POSTPONED UNTIL THE

HISTORICAL COMMISSION HAS FINISHED THEIR

REVIEW OF THE PROPOSED ORDINANCES
The Staff Report incorrectly summarizes the outcome of the August 18th meeting of the Historical Commission and minimizes the role the Commission is meant to play in the creation and implementation of ordinances impacting historical resources.

Initially, the Staff Report indicates that there is nothing in the zoning code that requires changes to be reviewed by the Historical Commission. However, the zoning code is not the area that creates the Historical Commission’s duty to review the proposed ordinances. Rather, under the municipal code, the Historical Commission “shall advise the city council, the planning commission and the agencies and departments of the city[,]” as well as specifically dictated in the City’s General Plan and policies. (Los Altos Municipal Code Section

2.12.030.) Importantly, the duty to advise the City Council, Planning Commission, and other City agencies is not permissive, as established by the use of “shall”. Further, the power and duty cited in the Staff Report, to review and comment upon existing or proposed ordinances, plans or policies of the city as they relate to historic resources, is not limited to ordinances solely in Title 12 Chapter 44. Rather, the review and comment duty is for any existing or proposed ordinance with the ability to impact historic resources. As such, the proposed ordinances clearly fall within the purview of the Commission and should have been sent to them for review from the very beginning. The fact that the proposed ordinances would be located in the zoning chapter of the municipal code does not have an impact on the Historical Commission’s power and duty to review and comment on these proposals.

Additionally, the Staff Report’s discussion of the August 18th review of these ordinances fails to reflect the Commission’s request for continued discussion and review of these ordinances by the Historical Commission. The video

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

recording of the meeting1 clearly establishes that continuing edits were needed on the proposed ordinances. The Commission repeatedly asked, and was given confirmation by the City, that any changes would be brought back to the Commission in October. For the Council to now act on these ordinances shows a complete disregard for the Commission’s role in historic resources, as codified in the municipal code. As such, the Council should respect and follow the municipal code’s clear procedure and allow for the Commission to continue and finalize their review of these proposals. To act now would be to undermine an important part of the City’s governing structure. PALLA urges the Council to postpone any activity on these proposals until the Commission has given their recommendation.

IV. THE PROPOSED ORDINANCE WOULD RESULT

SIGNIFICANT REDUCTION OF PUBLIC PARTICIPATION
Certified Local Government Programs are required to provide for adequate public participation in their local historic preservation programs. (Appendix G, Certified Local Government Application and Procedures.) Specifically, Appendix G highlights the following areas for public participation:

1. Public participation shall be fully encouraged at local commission meetings. Commission meetings shall be open to the public, with published agenda and minutes in accordance with the Ralph M.

Brown Act (G.C. Section 54950 et seq.) for open meetings. The published agenda shall be mailed in advance of meetings to individuals and citizen organizations interested in the commission’s activities.

2. Public participation shall be fully encouraged in the performance of the historic survey program at all levels of responsibility to identify and inventory significant cultural resources in the jurisdiction of the CLG. The public can serve as volunteers to assist in the survey effort. Survey results shall be of public record and on file at a public institution, except in the case of sensitive resources, e.g., archeological sites subject to vandalism.

3. Public participation shall be fully encouraged in the nomination process for the National Register of Historic Places program. The 1 August 18, 2025 Historical Commission Recording; available at https://www.youtube.com/ watch?v=w4FKC2nXrHA&t=7470s

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

CLG shall invite comments from the general public regarding National Register nominations.

4. Public participation shall be fully encouraged in all public hearings on projects related to CEQA and Section 106 processes.

As maintaining public participation in these areas is a clear requirement of the Certified Local Government Program, the City should consider revisions to the proposed ordinance, as outlined below.

A. The Proposed Ordinance Unnecessarily Limits the Public from Designating Public Historic Resources
Both the existing and proposed ordinance limit the public from identifying and seeking designation of historical resources, namely public properties. The City should revise the proposed ordinance to allow for any interested person or group within Los Altos to seek historical designation of a property based on the existing criteria. As the Office of Historical Preservation has made clear, historic resources are of interest to the entire community, not just individual property owners. By needlessly limiting who can seek historic designation of these community resources, the proposed ordinance would diminish public participation.

For example, the City of Whittier allows for any interested individual or group to seek designation of historic resources in the city.

Any person or group, including the city, may nominate a historic resource(s) for designation as a historic landmark or district by submitting an application to the planning department. Applications shall include, but are not limited to, submittal of the following:

A. Documentation indicating how the nominated resource
satisfies the designation criteria;
B. Any other information determined to be necessary for review of the proposed work; and
C. Required filing fees, as set by council resolution. City initiated nominations are not subject to filing fees.
(Whittier Municipal Code Section 18.84.070.)
In allowing for individuals and groups beyond property owners to seek designation of a property, the City would allow for greater protection of public

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

resources that may otherwise go undesignated and would preserve the public participation that is central to Certified Local Government Programs. This is especially relevant for City-owned properties that residents cannot otherwise nominate themselves with the current ordinance.

B. The Proposed Ordinance Would Dramatically Reduce the Ability of the Public to Appeal Decisions Regarding Historical Resources.

The changes to the Historic Preservation Ordinance include a dramatic change in who is allowed to appeal decisions impacting historical resources. Specifically, the proposed changes would remove the ability of any interested party to appeal a decision and would impose the limitations for appeals as outlined in Title 14 of the Municipal Code. This title limits appeals to property owners or residents within a 300-ft radius of the impacted property. (See Los Altos Municipal Code, Sec. 14.01.100.)
Limiting the appeal opportunities by an arbitrary radius ignores the fact that historic resources are of interest to the entire citizenry. In Drafting Historic Ordinances, the California Office of Historic Preservation notes that many cities have chosen to incorporate broad appeal rights into their preservation ordinances.

The community should consider what parties have the right to appeal decisions under the ordinance. Some communities, such as the City of Los Angeles, state in their ordinance that “an appeal may be filed by the applicant or any aggrieved party.” This broad authority allows any member of the community a right to appeal a preservation decision. Similarly, the City of Davis gives an unqualified right of appeal to “any resident of the city,” but requires that the appeal must have at least one advocate from within the local community.
(California Office of Historic Preservation, Technical Assistance Bulletin #14, Drafting Effective Historic Preservation Ordinances, p. 76.) If the City has actual interest in fostering a robust historic preservation program, including protection of broad public participation, the proposed amendment should be revised to ensure a broad right to appeal.

V. THE PROJECT WOULD REDUCE THE CITY COUNCIL’S

AUTHORITY OVER FUTURE PROJECTS

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

Historical preservation programs offer cities the ability to direct development that impacts historical resources. As city authority continues to be chipped away by statewide mandates surrounding development, historical ordinances allow cities maintain control over projects that would impact these historical resources. These programs offer cities a chance to have input on projects that would otherwise be taken out of local control due to streamlining efforts. By weakening the City’s preservation ordinance, the City will reduce its own ability to control development within Los Altos.

VI. THE PROJECT WOULD BE APPROVED IN VIOLATION OF

THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. The City’s Interpretation of CEQA Guidelines Section 15061(b)(3) is Flawed.

CEQA Section 15061(b)(3), also known as the common sense exemption, states that the exemption applies “[w]here it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment[.]” In making the determination that there is no possibility that the activity in question may have a significant effect on the environment, the City must make a factual review of the record to determine whether the exemption applies. As the California Supreme Court stated in Muzzy Ranch, “whether a particular activity qualifies for the common sense exemption presents an issue of fact, and the agency invoking the exemption has the burden of demonstrating that it applies.” Muzzy Ranch Co. v. Solano County Airport Land Use Com. (2007) 41 Cal.4th 372, 386.

Here, the City has failed to provide such a factual review. Rather, a single paragraph is provided in the Staff Report as support for the CEQA Exemption.

There are material differences between the existing and proposed historical ordinances that must be reviewed for environmental impact relating to the historical resources. Without such support, the City’s use of the common sense exemption is improper.

B. The Ordinances Will Have a Significant Impacts on Historical Resources
The adoption of the proposed amendment constitutes a project under CEQA. "To encapsulate the Muzzy Ranch test, a proposed activity is a CEQA project if,

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

by its general nature, the activity is capable of causing a direct or reasonably foreseeable indirect physical change in the environment." (Union of Medical Marijuana Patients, Inc. v. City of San Diego (2019) 7 Cal.5th 1171, 1198 [citing Muzzy Ranch Co. v. Solano County Airport Land Use Com. (2007) 41 Cal.4th 372].) Here, the Court determined that the City had incorrectly determined that the project was exempt from CEQA and should have continued with additional environmental review to determine the potentially significant impacts associated with the project.

CEQA Section 21060.5 defines the “environment” to include “historic” conditions within an area which will be affected by a proposed project.

According to Section 21084.1, a “project that may cause substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” (Emphasis added.) Here, the proposed amendment results in reduced oversight on developments impacting historical resources, the loss of appeal rights for the majority of community members, and the removal of the portions of the historical ordinance that discuss hardships and financial incentives, require separate advisory review by the Historical Commission, and note that a purpose of the historical preservation program is to fulfill the City’s CEQA and Federal Section 106 review responsibilities. These changes will result in significant, cumulative impacts on all of the City’s historic resources by reducing the efficacy of the protection embedded in the original ordinance. As such, the City must prepare an initial study and determine whether a Mitigated Negative Declaration or Environmental Impact Report is necessary for the project. Until additional CEQA analysis is performed, the City must refrain from adopting the proposed ordinance amendment.

The commonsense exemption from CEQA environmental review can only be relied upon “where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.” (CEQA Guidelines § 15061(b)(3).) The agency has the burden of providing substantial evidence, with both evidence and analysis, to provide the support for its decision that a project is exempt. (California Farm Bureau Federation v. California Wildlife Conservation Bd. (2006) 143 Cal.App.4th 173, 187; Davidon Homes v. City of San Jose (1997) 54 Cal.App.4th 106 [finding that the City failed to support its

Los Altos – Proposed Zoning Code Amendments for Historic Preservation October 14, 2025

decision to exempt an ordinance under the “common sense” exemption].) Here, no such support has been provided to support the findings. As such, the exemption is improper.

As the proposed ordinance directly impacts how the City treats historic resources, there is a reasonably foreseeable, direct change in the “environment” as it relates to the City’s historical resources. Thus, the significant impacts of the discretionary project upon historic resources must be reviewed through, at a minimum, an initial study.

I. CONCLUSION
PALLA requests that the pull the item from the consent calendar and reconsider the item at a future hearing date to allow for outstanding public input. PALLA additionally requests that the City formally review the environmental impacts of the proposed amendment through the preparation of an initial study considering the proposed ordinance’s significant impacts on the City’s historical resources. Further, PALLA requests that the City revise the proposed changes to ensure local engagement in decisions impacting historical resources is not arbitrarily limited. Lastly, PALLA urges the City to follow the procedure required by the CLG Agreement and Municipal Code by allowing the OHP and Historical Commission to review and recommend changes for these proposal prior to any final action taken by the City Council. If the City has any questions or concerns, feel free to contact my Office.

Sincerely,
______________________
Grace M. Holbrook
Attorneys for the Preservation Action League of Los Altos

1 Melissa Thurman
From: Catherine Nunes <[email protected]>
Sent: Tuesday, October 14, 2025 2:04 PM
To: Public Comment
Subject: Public Comment Oct 14 2025 Los Altos City Council Meeting Consent Calendar Item # 6:

Historic Preservation Ordinances - Request to Remove From Consent and Return to Historical Commission Review.

Dear Mayor and Council Members,
No one in Los Altos wants a dismantling of our historic and environmental protections. Or to reduce our treasured heritage spaces, sites, structures and public lands and their oversight to only items and code tied to Building and Construction under Zoning.

The purpose of a historical preservation ordinance is to align with the best principles and stewardship of our history and cultural assets for today and the future..

From the beginning, Los Altos has been committed to historic preservation in planning, policies, decisions and actions. In 1991, the City strengthened its historic preservation ordinance alongside its certification as a Certified Local Government.

The Council's position to waive the second reading of new Historic Preservation Ordinances and adopt these ordinances without formal review by the Historic Commission or justification on the intent and purpose of these new ordinances seems out of step with your commitment as governing representatives of the City of Los Altos.

These proposed major changes will negatively impact our historic and environmental resources, and our commitment to steward these historic resources in the public's best interests.

It seems reasonable to request that Item #6 for the Council to adopt these ordinances under Consent should not be voted on today. Instead, a vote to send back to the Historic Commission for review seems the right step in the right direction.

Sincerely,
Catherine Nunes

1 Melissa Thurman
From: [email protected]
Sent: Tuesday, October 14, 2025 2:22 PM
To: Public Comment
Subject: Online Form Submittal: Public Comment Submission to City Council Public Comment Submission to City Council
Submitting Written Comments on Agenda Items
Please note: Personal information, such as email addresses, telephone numbers, home addresses, and other contact information are not required to be included with your comments. If this information is included, they will become part of the public record. Redactions and/or edits will not be made to public comments, and the comments will be posted as they are submitted. Please do not include any information in your communication that you do not want to be made public.

Public comments submitted by 5:00 PM of the meeting date will be included in the agenda packet.

Public comments and any associated attachments are subject to the California Public Records Act.

Your Public Comment Regarding Agenda Item 10 for the October 14, 2025 Council Meeting
Please do not approve of synthetic turf for the proposed dog park. This material is neither aesthetically pleasing nor healthy for animals (including humans).

Thank you very much,
Caroline Horn
Los Altos Resident
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CITY OF LOS ALTOS

CITY COUNCIL MEETING MINUTES
TUESDAY, SEPTEMBER 30, 2025
7:00 p.m.
1 N. San Antonio Rd. ~ Los Altos, CA
Pete Dailey, Mayor
Neysa Fligor, Vice Mayor
Larry Lang, Councilmember
Sally Meadows, Councilmember
Jonathan D. Weinberg, Councilmember
CALL MEETING TO ORDER – Pete Dailey, Mayor, called the meeting to order at 7:00 p.m.

ESTABLISH QUORUM – All Councilmembers were present.

PLEDGE OF ALLEGIANCE – Pete Dailey, Mayor, led the Pledge of Allegiance.

REPORT ON CLOSED SESSION
There was no Closed Session meeting.

CHANGES TO THE ORDER OF THE AGENDA
There were no changes to the order of the agenda.

PUBLIC COMMENTS ON ITEMS NOT ON THE AGENDA
The following member of the public spoke during Public Comment:
• Kirsti Elder

CONSENT CALENDAR
The following members of the public spoke on an item on the Consent Calendar:
• Nathan Godderis (Item 4)
• Maria Bautista (Item 6)
Motion by Lang and Second by Meadows to approve the Consent Calendar. Motion carried unanimously by roll call vote.

1. Approve Draft Meeting Minutes for the Special and Regular Meeting of September 9, 2025

2. Approval of Short-Term Seat of Parks, Arts, Recreation & Cultural Commissioner
Approve the short-term seat of Parks, Arts, Recreation & Cultural Commissioner (PARC)

3. Adoption of Resolution - Comprehensive General Plan Update - Professional Services Agreement
Adopt a Resolution authorizing the City Manager to execute a professional services agreement with Dyett & Bhatia for the preparation of a comprehensive General Plan Update and associated Environmental Impact Report (EIR)

City of Los Altos
City Council Regular Meeting Minutes
September 30, 2025

4. Adoption of Resolution – Outdoor Fitness Equipment Replacement at Hillview Park
Adopt a resolution to authorize the City Manager to enter into an agreement with Greenfields Outdoor Fitness, Inc. to design, purchase, and install outdoor fitness equipment to replace the old fitness equipment at Hillview Park in an amount not to exceed $145,000

5. Adoption of Resolution - Contract Amendment for Fremont Bridge Pedestrian Bridge
Adopt a resolution authorizing the City Manager to execute Amendment No. 1 on behalf of the City with Dewberry Engineers Inc. in the amount of $17,228 and authorize additional $30,000 contingency for design professional consulting services for the Fremont Avenue Pedestrian Bridge Rehabilitation Project, TS-01055, for FY2025/26, and find that this action is Exempt from Environmental Review Pursuant to Section 15301(c) of the State Guidelines Implementing the California Environmental Quality Act of 1970

6. Adoption of Resolution - Accepting North Council Library Authority Funds for Main Library Improvements Project
Two actions for Council consideration:
• Adopt a resolution accepting North County Library Authority Funds for Main Library Improvements Project, Recognize $1,254,000 Revenue from North County Library Authority, and Appropriate $1,254,000 Revenue to Main Library Improvements Project (LI01001).
• Adopt a resolution authorizing the City Manager to amend the contract with Anderson Brule Architects for the Main Library Improvements Project in an amount not to exceed $1,254,000, inclusive of a 10% contingency, and to execute any necessary change orders within that amount on behalf of the City

PUBLIC HEARING

7. Introduction of Ordinances - Zoning Code Amendments for Historic Preservation and Mills Act
Four actions for Council consideration:

Introduce and waive first reading of draft ordinances and consider June 5, 2025, Planning Commission recommendation for the adoption of the proposed ordinances, which include:
• An Ordinance of the City Council of the City of Los Altos Adding Chapter

14.93 (Historic Preservation) to the Los Altos Municipal Code; and • An Ordinance of the City Council of the City of Los Altos Adding Chapter

14.95 (Mills Act Program) to the Los Altos Municipal Code; and

City of Los Altos
City Council Regular Meeting Minutes
September 30, 2025

• An Ordinance of the City Council of the City of Los Altos Repealing in its Entirety Chapter 12.44 for Existing Historic Preservation Regulations; and • Find that the proposed amendments are exempt from environmental review pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines
Neysa Fligor, Vice Mayor, recused herself from the discussion and consideration of the item due to a potential conflict of interest.

Nick Zornes, Assistant City Manager, presented the report.

Pete Dailey, Mayor, opened the Public Hearing.

The following members of the public spoke during the Public Hearing:
• Jon Baer • Daniil Reouk
• Lois Baer • Acorn Pooley
• Roberta Phillips • Warren Yang
• Maria Bautista • Alice Mansell
• Kirsti Elder • Teresa Morris
Pete Dailey, Mayor, closed the Public Hearing.

The City Council amended the ordinances to affirm the decisions made by the Planning Commission at its meeting on June 5, 2025.

Motion by Weinberg and Second by Meadows to Introduce an Ordinance by title only of the City Council of the City of Los Altos, adding Chapter 14.93 (Historic Preservation) to the Los Altos Municipal Code, as amended. Motion carried 4-0 by roll call vote with Vice Mayor Fligor recused.

Motion by Weinberg and Second by Meadows to Introduce an Ordinance by title only of the City Council of the City of Los Altos, adding Chapter 14.95 (Mills Act Program) to the Los Altos Municipal Code, as amended. Motion carried 4-0 by roll call vote with Vice Mayor Fligor recused.

Motion by Weinberg and Second by Meadows to Introduce an Ordinance of the City Council of the City of Los Altos repealing in its Entirety Chapter 12.44 for Existing Historic Preservation Regulations and to find that the proposed amendments are exempt from environmental review pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines, as amended. Motion carried 4-0 by roll call vote with Vice Mayor Fligor recused.

The City Council took a recess at 8:53 p.m.

The City Council reconvened at 9:04 p.m.