From: Robert Hall
To: Council, City
Subject: Public comment, Item 9: Turf Systems Assessment Date: Monday, November 17, 2025 11:04:48 AM
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i
RE: 9. Approval of the Study and Assessment of Turf Systems: Findings and Recommendation for El Camino Park Synthetic Turf Replacement as Recommended by the Parks and Recreation Commission; CEQA status - categorically and statutorily exempt.
Dear Members of the Palo Alto City Council:
Thank you for the opportunity to comment on the turf-field replacement decision before you— particularly the discussion regarding the fields at El Camino Park and the broader implications of synthetic (“artificial”) turf versus natural grass in our city parks.
I urge you to
reject
the installation of new artificial turf and instead embrace well-managed
natural grass
that better aligns with the City’s sustainability, health and long-term-cost goals.
My comments are informed in part by the City’s recently released turf study on synthetic vs natural athletic fields.
paloalto.gov+2paloalto.gov+2
Key reasons why artificial turf is the wrong choice for Palo Alto:
1. Environmental and health risks from plastics, infills and micro-pollutants.
Synthetic turf is made of plastic fibres and infill materials (often rubber, sand, cork, or other options) which degrade over time and can release micro-plastics, rubber granules, and chemical additives into the surrounding soils, drainage, and air.
Wikipedia+1
The City report specifically raises concerns about emerging chemical issues (for example PFAS/“forever chemicals”) in synthetic turf installations.
San José
Spotlight+1
Unlike natural grass, synthetic turf offers no ecosystem service of soil- sequestration, transpiration cooling, or biotic soil life. Once installed, it acts as an impermeable or semi-impermeable surface with less ecological benefit.
2. Life-cycle, disposal and long-term cost issues.
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While artificial turf may appear to reduce mowing or watering in the short term, the long-term costs (replacement of the turf carpet, disposal of worn-out synthetic mats, infill replenishment, seam repairs, etc.) are significant and often under- accounted for. The City’s own study emphasizes a life-cycle cost analysis of the alternatives. paloalto.gov
+1
Disposal of synthetic turf is problematic: many turf fields are only usable for a defined lifespan (e.g., 8-12 years), and the worn-out materials often go to landfill or worse. The study advises that the City considers end-of-life management in its evaluation. paloalto.gov
3. Reduced ecosystem services and climate resilience.
Natural grass contributes to cooling (via evapotranspiration), infiltration of storm water, carbon sequestration (albeit modest), and supports soil microbial life. In a warming climate and with storm-water/run-off concerns, natural turf is more aligned with sustainability goals.
Artificial turf surfaces absorb solar heat and raise local surface temperatures significantly compared to grass, thereby increasing urban heat island effects and making fields less comfortable, especially during hot summer afternoons.
4. Maintenance, injury and field-use trade-offs.
Some proponents of synthetic turf argue the ability to support very high-use athletic scheduling. However, I would caution: higher usage means greater degradation, faster heat exposure, and ultimately faster replacement.
The City of Palo Alto study acknowledges that greater hours of play on synthetic turf must be weighed against durability and health concerns. paloalto.gov +1
While natural grass does require thoughtful maintenance (irrigation, mowing, aeration, rest periods), Palo Alto already has a strong parks program and community capacity to maintain grass fields sustainably, especially given our mild climate and local water-efficiency advances.
5. Alignment with Palo Alto’s sustainability values and policies.
The City has committed to strong climate, zero-waste, and environmental justice goals. Choosing a plastic-based field replacement runs counter to these values: it places a heavy-plastic, high-energy, disposal-intensive infrastructure at the heart of a public park.
In light of the study’s recommendation to include “compatibility of field options with Palo Alto’s broader sustainability and climate action goals” in the evaluation process, the decision to go synthetic must show strong, defensible rationale that it does more good than harm. San José Spotlight
+1
Why natural grass is the better choice for Palo Alto:
With proper drainage, irrigation, soil health programs (compost, organic amendments), and scheduled rest/rotation, natural grass can be a durable, resilient field surface that supports athletics and ecological health.
Natural grass supports the goals of open-space parks—not just as athletic fields—but as green infrastructure, air-cooling, neighborhood amenity, and place for community relaxation.
It avoids the plastic burden, avoids disposal issues, and keeps us aligned with a longer- term mindset (not just “install now, dispose in 10 years”).
Maintenance costs can be stabilized through best practices (reduce water use via drought-tolerant species, smart irrigation, turf-grass blends suited for our climate) and the City can invest in monitoring and adaptive management rather than overseeing a plastic carpet replacement treadmill every decade.
Recommendations for the City Council to adopt:
Before approving any synthetic turf installation, require a full life-cycle cost and environmental impact comparison (including manufacturing, transport, installation, maintenance, disposal) between synthetic turf and a best-practice natural grass rebuild (or hybrid system). The City’s own study provides this framework. paloalto.gov Prioritize field redesign so that natural grass becomes the standard unless a very compelling case is shown that synthetic turf offers significantly greater public benefit and minimal environmental trade-offs.
If synthetic or hybrid turf is proposed, ensure stringent specification of materials (low or zero PFAS infill, guaranteed recyclability, documented disposal/recycling plan, heat- mitigation design) and full disclosure of usage hours, maintenance costs, expected lifespan, and replacement/disposal.
Invest in ongoing soil health and turf-grass management programs so that natural grass fields in Palo Alto become long-lived, high-functioning assets rather than planning for frequent replacement.
In conclusion: The choice of field surface is not just a “mowing vs no mowing” operational question—it is a substantive sustainability decision for the City of Palo Alto. By choosing natural grass over plastic-based artificial turf, the City will uphold its environmental leadership, reduce long-term risk and cost, deliver athletic fields that serve the community and the climate, and avoid the hidden burdens of plastic infrastructure. I strongly urge the Council to direct staff to prioritise natural grass rebuilds for El Camino Park (and other City-owned fields) and to only consider synthetic turf as an exception after rigorous comparative analysis.
Thank you for your time and for your leadership in stewarding Palo Alto’s parks for present and future generations.
Bob Hall
San Francisco, 94117
From: Pam Bond
To: Council, City
Subject: Public Comment Action Item 9, Approval of the Study & Assessment of Turf Systems Date: Monday, November 17, 2025 10:30:00 AM
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Dear Palo Alto City Councilmembers,
Please see attached my comments regarding the Study and Assessment of Turf Systems. Consider the full life cycle of the plastic journey from manufacture to end of life. I am sharing local examples of plastic blade loss and storm water pollution in hopes that you will carefully consider the environmental harm that these plastic fields perpetuate.
Sincerely,
Pam Bond
2025.11.17 Palo Alto City Council - caution regar…
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From: Claire E
To: Council, City
Subject: El Camino Park Turf causing Plastic Pollution
Date: Monday, November 17, 2025 9:49:49 AM
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Dear Council members,
I sent you a list of concerns related to the Lloyd study and installation of more synthetic turf at El Camino Park (see below.) Today I am sending photographs I took at El Camino Park. It had recently rained but was not raining at the time. So no water was running toward the storm drain but it was clear that plastic grass blades were migrating off of the field and into the storm drain.
Photos below include a Google map image with the storm drain labeled. In the following photos, you can see the plastic grass blades migrating across to DG path, collecting in fall leaves, and on the storm drain grate. Many had also entered the drain and it is certain that a lot had already entered a creek. On the map image you can also see El Palo Alto, the namesake tree of Palo Alto on the banks of San Francisquito creek. So although it is an urban area, there are important ecosystems to protect from plastic and its toxic components, as well as human health.
Thank you for your time and attention,
Claire Elliott
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1. Lloyd study should not be approved in its current biased and incomplete form:
a.
A large concern is the poor attention paid to the health impacts of synthetic turf.
i.
The “Heath Hazards” section lists one chemical hazard for synthetic grass (PFAS) and several for natural grass, even though the chemicals listed for natural grass are all pesticides that Lloyd must know Palo Alto does not use.
1. The report downplays the PFAS concern by saying the city can procure PFAS free turf.
a.
This is a serious problem because it is not yet possible to confirm any product is PFAS free, due to the large number of PFAS compounds that could be incorporated into feed stocks used by the turf manufacturer.
b.
Many of these compounds have no approved analytical
method to identify their concentration in a material.
ii.
In addition, synthetic turf often contains a large number of compounds besides PFAS that are known to be toxins, carcinogens and endocrine disruptors.
iii.
Also during its use, plastic grass blades often break off and then turn into microplastics which are known to have many negative health and environmental impacts.
b.
A second concern is uneven focus of environmental concerns for all three turf types evaluated by the study.
i.
No more mention of PFAS is made, in this case the only concern about synthetic turf is the release of microplastics.
ii.
For hybrid and natural grass, carbon footprint and water use were described, but not for synthetic turf even though its carbon footprint is high and water is used in washing and cooling the turf. Sometimes antibacterial solutions are also used which can be released into the environment.
iii.
No other chemical releases form synthetic grass is mentioned (like health impacts they should have include the thousands of chemicals that can be included and leached out of synthetic turf, including many that are toxins, carcinogens and endocrine disruptors.
c.
The cost figures are also misleading in the final report. i.
The cost per hour calculated for natural grass fields assumes these fields are only used for an average of 500 hours per year when the study itself lists nine grass fields in Palo Alto that are currently used over 1,000 hours per year.
ii.
The cost per hour for synthetic turf assumes El Camino was used for 2700 hours per year. This calculation included some “double-dipping” because when the two halves of the field were used at the same time, two instead of one hour was used. The consultant admitted if this method is changed, the usage would be 1,900 instead of 2700 hours per year. It should be changed because the cost for installing and maintaining the fields is based on the full sized field, not half of a field! iii.
When you redo the cost estimate per hour of usage, these corrected numbers result in the cost per hour for grass changing from $179 to $89 and synthetic turf changing from $79 to $92. Showing natural grass can cost less.
iv.
The cost for synthetic turf would go up further from $92/hour of play if you include the cost for recycling the turf which was left out of the study.
v.
The cost for synthetic turf would go up even farther if the study included an estimated cost for the environmental and health impacts of synthetic turf during manufacture, use and disposal.
vi.
In the October 28th Parks and Recreation meeting, the Lloyd consultant stated that recycling turf is expensive so the turf might be repurposed for batting cages, as substrate for horse arena soils or shipped south of the border. What is the eventual fate of these “repurposed” turf fields? vii.
What is the economic impact of synthetic turf chemicals and microplastics in our soil and waterways, the cost to clean up contamination caused by reuse and disposal, or the price of medical bills and shortened life spans for those in plastics manufacturing industries who are known to have significantly higher cases of many diseases?
2. One recommendation of the Lloyd study that makes a lot of sense is to design and implement a pilot project of a well-designed and maintained grass field. a.
This would allow Palo Alto to gather data to compare costs and carrying capacity of a high quality organic grass field with drought resistant grasses and good surface drainage. These types of fields have been shown in other parts of the country and world have provided up to 2,000 hours of use per year. b.
This pilot project would be ideally implemented now at El Camino Park. The design could start this year and by installing sod instead of seeding you could shorten the project timeline.
c.
The lighted field at El Camino would also allow extended play many grass fields in Palo Alto do not offer.
d.
Saying no to plastic grass and implementing a natural grass pilot project would help Palo Alto maintain a reputation as an environmental leader and avoid the well known environmental and human health impacts of a synthetic field before, during, and after its useful life.
3. The Lloyd study gives little detail about what a pilot project design should include.
Some ideas include:
a.
Partner where possible with the county, other cities in the region, school district, etc, so the costs and results can be shared regionally. b.
Develop the plan with expert help of agronomists who have already had success designing and maintaining organic grass fields. Beyond pesticides may be able to provide some of this expert help at no or low cost to the city. c.
Save money and water and make organic management more successful by NOT using a sand capped field. Provide internal drainage by amending the native soils with organics, and aerating often. Provide surface drainage with careful grading that provides a smooth surface with a slight crown in the middle.
d.
Include high efficiency irrigation (e.g. MP rotators) to mimic rainfall and reduce drift and puddling of water.
e.
Selects a grass species that has been shown to allow additional play time (possibly a warm season grass that has been shown to work in California.) f.
Use organic management that adds carbon and nutrients that are less likely to runoff into stormdrains.
g.
Grass field monitoring and maintenance is critical. Increase the budget for these necessities. Ensure contracts for maintenance are detailed, hold back funding to ensure the contractor performs well.
h.
Control gophers and fill holes and ruts caused by animals, people, vehicles, etc.
i.
Ensure maintenance protocols are detailed in contracts and funding held aside until contractors prove they are following the required protocols. Ask for logs of maintenance and photo documentation of improvements made. j.
Develop an easy to access and use crowd sourcing method of evaluating field conditions (online tool for reporting gopher holes, irrigation problems leading to dry or soggy conditions, etc.
k.
Use adaptive management to alter practices as results from monitoring show improvements are needed.
From: Alice Smith
To: Council, City
Subject: Artificial Turf
Date: Sunday, November 16, 2025 8:56:17 PM
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I urge the city of Palo Alto to ban artificial turf anywhere in city owned property in Palo Alto: not only on playing fields, , at parks, everywhere. We need to stop runoff with poisonous chemicals, let the earth breath and allow worms, bugs and grass to be part of our landscape, enhancing the quality of our town.
We should ask our community members to change from grass to wild grasses if practicable, and to remove artificial turf because the turf is polluting the streams, increasing runoff and killing the natural soil under it.
We re supposed to be an environmentally aware city, proud of our certifications for new buildings, but then you put chemicals down instead of grass and pollute our streams, expose children to dangerous chemicals. Why? Because you might not have to mow grass and keep it growing.
"Turf is harmful to health, safety, and the environment. It contributes to urban heat as turf field surfaces can get anywhere from 40-70 degrees Fahrenheit hotter than
surrounding areas on hot days. Because of this, injuries such as turf burn and heat stroke are more common on artificial turf fields.
Additionally, artificial turf contains harmful chemicals such as PFAS, a class of toxins linked to cancer and reproductive harm which can be dangerous to users of artificial turf fields. Artificial turf also poses a threat to the environment and aquatic wildlife when chemicals like PFAS and particles like microplastics get washed into our waterways.
By banning new artificial turf on city land and using natural grass fields instead, the county can protect people and the environment." (Save Our Bay) Alice Schaffer Smith
850 Webster Street #520
Palo Alto, CA 94301
650 283 2822
From: Leanne McAuliffe
To: Council, City
Subject: (Frustrated) Public Comment - Meeting Nov. 17, 2025 - Action Item 9, Approval of the Study & Assessment of Turf Systems
Date: Saturday, November 15, 2025 10:49:49 AM
Attachments: TigerTurf-Championship-Plus-1.625-in-56-oz-Spec-Sheet.pdf Pivot specs.pdf
Brown lead n1782_astroturf_cj,_final-signed (1).pdf
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Dear Palo Alto City Councillors,
Below is an email I sent to Parks and Rec. In summary:
There is a standard for lead of <50 parts per million for artificial (plastic) turf in California.
Some in the plastic turf industry are defining "non-detectable" for lead as <100 parts per million.
Simple math shows 100 parts per million is double the California standard for plastic turf.
The Parks and Rec response to my simple math was that they (consciously) didn't include lead in the report and that "lead thresholds for synthetic turf have been established by the State." So it seems they did not even read my email. I know there is a threshold BUT for some products there's no sure indication these thresholds are being met!! And NO ONE is keeping the plastic turf industry in check. The plastic turf industry is self-regulating! So, as Councillors who make the final (conscious) decision on this report, please SIMPLY require that the Final Turf Report include:
the health impacts of lead on children and why they are more vulnerable to toxic effects,
the California state standards for lead in artificial turf, the attached Consent Judgment in the report's appendix.
In line with this please then use your power to protect our kids and require that ALL (if any) artificial turf components selected for Palo Alto City MUST be under the 50 parts per million lead limit in line with the California standard and that this must be proven with lab reports from an independent laboratory. Better still, if you want to implement the most This message needs your attention
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precautionary measures for our kids, demand the lead limit be set to zero parts per million given that the CDC has stated "NO safe blood lead level in children has been identified and the effects of lead exposure cannot be corrected." Please do not let the issue of lead fall under the radar.
Even better still, avoid unnecessary exposure to any lead, PFAS, microplastics or any cocktail of other chemicals in plastic turf and chose real turf for field replacements and renovations.
What you ultimately decide will not only protect children and youth in your own city but also those in surrounding cities and towns that will follow your lead.
Kind regards,
Leanne McAuliffe
Santa Clara county resident
From: Leanne McAuliffe <[email protected]>
Sent: Wednesday, September 3, 2025 1:09:06 PM
To: Kristen.O'[email protected] <Kristen.O'[email protected]>; [email protected] <[email protected]> Subject: Synthetic Turf and Natural Grass Turf study - Draft Report - Please incorporate lead standards
Dear Palo Alto City Community Services Director Kristen O’Kane and Parks and Recreation Commission Chair Nellis Freeman,
With regard to the Turf Study Draft Report, please include lead in this draft report and set a standard that either requires artificial turf products have ZERO lead in them or that they at least have <50ppm (less than 50 Parts Per Million).
The only reference to lead that I can find in this entire draft report is in the appendix in a County of Santa Clara, Office of The County Executive communication to the Board of Supervisors. See pages:
- 663 (& 739 where the same document is repeated) where there is reference to the fact there is no safe level of blood lead.
- 701 (& 777 again in repeated document) where lead was found in tire crumb infill above CA DTSC levels and EPA regulatory limits.
This is disturbing because lead has been a huge issue for artificial turf in the past and it should not be left to fall completely off the radar. (Lead issues do not only apply to the tired crumb rubber infill so removing this as an infill option doesn't necessarily remove the lead risk.) Lead was found in artificial turf at dangerously high levels and as a result a standard for artificial turf was set in 2009 by then Governor Brown limiting lead in artificial grass carpet to <50ppm from 2010 (with an exception ONLY for field lines of <100ppm). However, some companies apply <100pm to their entire product and at times even equate this to "lead free".
As a concerned parent and consumer, I would expect "lead free" to mean ZERO lead. Anything other than that should be transparently defined to allow informed consumer choice. Likewise, anyone using the final version of this draft report should be able to make a fully informed judgement and decision.
Some products are confusing when it comes to lead content. For example, TenCate, who have been promoting their latest product, Pivot, have lab reports simply stating that Pivot has <100ppm lead content. This doesn't meet the <50ppm standard set by Governor Brown. In the event that the Pivot product actually has less than 50ppm, Tencate were asked months ago to define exactly how many ppm of lead the Pivot product has but no answer was received. Likewise, Tiger Turf is marketed as lead free and yet lab reports simply state <100ppm lead content. Always Green Company even inaccurately states the standard to be <100ppm with a certificate stating Tiger Turf to be "Lead Free" but the certificate itself defines this as no "detectable" traces of lead. Does this just mean no lead detected over 100ppm since lab reports simply state the lead level to be <100ppm? This alone would not meet the <50ppm standard.
We all know that lead is a huge problem when it comes to children's health and the CDC has stated "NO safe blood lead level in children has been identified and the effects of lead exposure cannot be corrected." Given how much artificial turf can disintegrate over time, any lead content in artificial turf is concerning. Hence, the safest level is really zero.
Since the report is about being proactive and not reactive please don't allow scenarios like that in New Jersey in 2012 reoccur. Back then extremely unsafe levels of lead had been found in plastic grass fields. At that time only 5 of 50 schools allowed their fields to even be tested for lead. So 45 refused? Basically, it seemed school funds took priority over children’s health.
We can’t have this happening again with any toxin be that lead, PFAS or any other chemical for that matter.
When looking at El Camino Park, have funds already dictated decisions? I was at this park on a cloudless May morning at 11am and the temperature was only F65 and yet the artificial turf field was already F129.5. Even on this cool morning the smell of the field was nauseating. I could not imagine what it was like for kids/youths playing on that field in those temperatures let alone warmer temperatures. I appreciate the original infill was a disaster and that it was "fixed" but there was still a lot of the original infill in the field even all after those years, so was it really "fixed" sufficiently? Or did funds dictate how well the issue could be addressed? So, in line with making the draft report as robust as possible to avoid issues for users, the environment or public funds, please also incorporate some basic lead information and standards into this report for all artificial turf components (preferably ZERO, but at minimum <50ppm) especially since the primary users, kids and youths, are also the most vulnerable to the effects of any toxins.
Kind regards,
Leanne McAuliffe
Santa Clara Resident
(Though I am not a Palo Alto resident I know my own town, Los Gatos, has eagle eyes on this report so it is incredibly important to me that your report more robustly protects our kids and youths.)
SIDE NOTE: the attached TenCate document markets the Pivot product as no infill, no microplastics, no PFAS, but:
"no infill"? (they also state later that a cooling infill is available to help deal with heat issues - Santa Clara County has a hot climate),
"no microplastics"? (if you visit John Mise Park you'll see a whole lot of microplastics from the Pivot field there), and
"no PFAS"? (on TenCate's website it says artificial turf has less than 100ppm PFAS which does not equal "no" PFAS) Just like other industry claims like "lead free" these statements cannot always be taken at face value. https://oag.ca.gov/news/press-releases/brown-creates-nations-first-enforceable-lead- standards-artificial-turf
Brown Creates Nation's First
Enforceable Lead Standards for
Artificial Turf - State of California -
Department of Justice - Office of the
Attorney General
OAKLAND-Fighting to ensure the safety of children’s
playgrounds and ball fields, Attorney General Edmund G.
Brown Jr. today signed off on an agreement requiring
Georgia-based AstroTurf, LLC to virtually eliminate lead from its artificial grass, creating the country’s first enforceable lead standards for artificial turf products. “As schools and daycare centers replace grass with ...oag.ca.gov https://alwaysgreensyntheticgrass.com/artificial-grass-safe-families-pets/ https://peer.org/lead-limits-needed-on-tire-crumb-playgrounds/ Lead Limits Needed on Tire Crumb
Playgrounds - peer.org
Lead Limits Needed on Tire Crumb Playgrounds CPSC
Ruling on Artificial Play-Areas as Children’s Products
Sought Washington, DC — The Consumer Product
Safety Commission (CPSC) should prevent children from
being exposed to lead and other harmful heavy metals in playgrounds and school sports fields made from
shredded tires, according to a formal request for an
advisory opinion filed by Public ...peer.org
Combining durable XPS slit film and playable Diamond
monofilament fibers with thatch at the base, players
get a heavier, more consistent playing surface.
The texturized monofilament thatch helps to reduce infill splash, decrease infill migration and provide additional shock absorption. Teams will enjoy a field that not only looks great, but feels and plays great, as well.
CHAMPIONSHIP+
TENCATE GRASS | 1131 BROADWAY ST. DAYTON, TN 37321 | (855) 773-6668 | VERSION 2023 TIGERTURF CHAMPIONSHIP+ SPECS
YARN
DENSITY (DENIER) 10,000/1 (XPS),
12,000/6 (XWRD),
5,000/8 (thatch)
THICKNESS (MICRONS) 120 (XPS); 365 (XWRD),
100 (thatch)
MELTING POINT 128° C | 260° F
BREAKING STRENGTH 24 lbs/force (XPS/XWRD);
17.3 lbs/force (thatch)
LEAD CONTENT (PPM) <100
Pile Height, Max Thickness, Face Weight, Primary & Secondary Backing, and Total Weight can differ by ±10%. The Stitch Rate will change according to the exact specifications and can differ by ±1. Roll Width can differ by ±0.8 inch.
TenCate Grass has the right to alter each product specification in order to improve the system according to the latest standards. TenCate Grass is not legally liable in case of noncompliance with the above mentioned specifications. *Face Weight reflects entire length of yarn, including portion woven into backing, which is consistent with standard ASTM method of measuring tuft including back stitch. **For details on thatch color, refer to the Standard Color Sheet. ***Lime Green is shown for color reference only. Lime-only turf is not available.
BEST FOR BASEBALL,
SOFTBALL, INDOOR AND
MULTI-PURPOSE FIELDS
TURF
PILE CONTENT TenCate U.V. resistant XWRD,
monofilament and TenCate U.V. resistant
XPS Plus slit film combined with
TenCate TXT monofilament
root zone
PRIMARY BACKING 7.5 oz/yd2; TenCate K29 Backing (Double Layer Thiobac, black, U.V. stabilized;
Layer 1: 100% PP, Layer 2: PET/PP blend)
SECONDARY BACKING 20 oz/yd2 Polyurethane coating with
drainage holes
TOTAL WEIGHT 83.5 oz/yd2
PILE HEIGHT 1 5/8 inch
FACE WEIGHT* 56 oz/yd2
MACHINE GAUGE 1/2 inch
SET UP 2 ends/needle, A/B (face fibers)
ROLL WIDTH 182 inch
WATER PERMEABILITY > 50 inches/hour
TUFT BIND (ASTM D1335) > 8 lbs
GRAB TEAR (ASTM D5034) 250/250 lbs
PILL FLAMMABILITY (ASTM D2859) Pass
-
BLEND OF MONOFILAMENT AND
SLIT FILM FIBERS WITH TEXTURIZED
MONOFILAMENT
STANDARD COLORS**
NAVY BLUE
Pantone: 282C
FLORIDA BLUE
Pantone: 281C
BROWN
Pantone: 1545C
GRAY
Pantone: 422+429
RED
Pantone: 185C
BLACK
Pantone: 000C
BLUE LAGOON
Pantone: 2925C
ORANGE
Pantone: 166C
RED CLAY
Pantone: 7526C
CRIMSON
Pantone: 202C
TAN
Pantone: 728C
BLUPLE
Pantone: 268C
BRIGHT YELLOW
Pantone: 136C
VEGAS GOLD
Pantone: 466C
WHITE
Pantone: 000
FIELD GREEN
Pantone: 575C
LIME GREEN***
Pantone: 7496C
FIELD GREEN/
LIME GREEN
WHEN USED WITH LIGHTWEIGHT INFILLS
No Infill. No Microplastics. No PFAS.
Pivottm by TenCate is a true game changer. Designed with extensive feedback from top-level athletes, Pivottm by TenCate provides ultimate performance, maximum player comfort and ultra-durability.
The unique combination of yarns plays and responds like the best natural grass and will perform at Year 10 like it does on Day 1. Additionally, Pivot tm by TenCate is the environmentally-friendly choice – no infill is needed and real-grass feel is achieved without any resource intensive maintenance.
PIVOT
BY TENCATE
TM
TURF
PILE CONTENT TenCate XP+ U.V. resistant slit film,
combined with TenCate semi-TXT
and TXT monofilament root zone.
PRIMARY BACKING 7.5 oz/yd2; TenCate K29 Backing (Double Layer Thiobac, black, U.V. stabilized,
Layer 1: 100% PP, Layer 2: PET/PP blend)
SECONDARY BACKING 20 oz/yd2 Polyurethane coating with
drainage holes
TOTAL WEIGHT 117.5 oz/yd2
PILE HEIGHT 1 1/8 inch
FACE WEIGHT* 90 oz/yd2
MACHINE GAUGE 3/8 inch
SET UP 3 ends/needle
ROLL WIDTH 182 inch
WATER PERMEABILITY 64 inches/hour (unfilled)
TUFT BIND (ASTM D1335) > 9 lbs
GRAB TEAR (ASTM D5034) 274 lbs length, 395 lbs width
PILL FLAMMABILITY (ASTM D2859) Pass
-
TENCATE AMERICAS | 1131 BROADWAY ST. DAYTON, TN 37321 | (855) 773-6668 | TENCATEGRASS.COM | VERSION 202
BEST FOR SOFTBALL, BASEBALL
AND WARNING TRACKS.
YARN
DENSITY (DENIER) 5,040/1 (XP+);
5,400/6 (semi-TXT);
7,200/10 (TXT)
THICKNESS (MICRONS) 100 (XP+);
152 (semi-TXT);
145 (TXT)
MELTING POINT 128° C | 260° F
BREAKING STRENGTH 11 lbs/force (XP+);
20 lbs/force (semi-TXT);
20 lbs/force (TXT)
LEAD CONTENT (PPM) <100
BLEND OF DURABLE SLIT FILM AND
SEMI-TEXTURIZED AND TEXTURIZED
MONOFILAMENT FIBERS
Pile Height, Max Thickness, Face Weight, Primary & Secondary Backing, and Total Weight can differ by ±10%. The Stitch Rate will change according to the exact specifications and can differ by ±1. Roll Width can differ by ±0.8 inch.
TenCate has the right to alter each product specification in order to improve the system according to the latest standards. TenCate is not legally liable in case of noncompliance with the above mentioned specifications.
*Face Weight reflects entire length of yarn, including portion woven into backing, which is consistent with standard ASTM method of measuring tuft including back stitch.
PIVOT BY TENCATE 1.125" SPECS
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EDMUND G. BROWN JR., Attorney General
J. MATTHEW RODRIQUEZ, Chief Assistant Attorney General
KEN ALEX, Senior Assistant Attorney General
EDWARD G. WEIL, Supervising Deputy Attorney General
DENNIS A. RAGEN, Deputy Attorney General, Bar No. 106468 110 West A Street, Suite 1100
San Diego, California 92186-5266
Telephone: (619) 645-2016
Fax: (619) 645-2012
CARME
N A. TRUTANICH, Los Angeles City Attorney
EARL E. THOMAS, Chief of Criminal and Special Litigation PATRICIA BILGIN, Assistant City Attorney, Environmental Justice Unit ELISE RUDEN, Deputy City Attorney, Bar No. 124970
VAUGHN MINASSIAN, Deputy City Attorney, Bar No. 203574
200 North Main Street, 500 City Hall East
Los Angeles, California 90012-4131
Telephone: (213) 978-8080
Fax: (213) 978-8111
DAVID W. PAULSON, District Attorney of Solano County
CRISELDA B. GONZALEZ, State Bar No. 146493
Senior Deputy District Attorney
675 Texas Street, 4th Floor, Suite 4500
Fairfield CA 94533-6396
Telephone: (707) 784-6859
Fax: (707) 784-9001
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF ALAMEDA
PEOPLE OF THE STATE OF CALIFORNIA,
ex rel. EDMUND G. BROWN, JR., Attorney
General, CARMEN A. TRUTANICH, Los
Angeles City Attorney, DAVID W.
PAULSON, Solano County District Attorney
Plaintiff,
v.
BEAULIEU GROUP, LLC, et al.
Defendants
Case No. RG 08407310
CONSENT JUDGMENT AS TO
DEFENDANT ASTROTURF , LLC
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28 1. INTRODUCTION
1.1 On September 2, 2008, the People of the State of California (“People” or “Plaintiffs”), by and through the Attorney General of the State of California (“Attorney General”), the Los Angeles City Attorney and the Solano County District Attorney, filed a complaint for civil penalties and injunctive relief for violations of Proposition 65 and unlawful business practices in the Superior Court for the County of Alameda. The People’s Complaint alleges that the named Defendants failed to provide clear and reasonable warnings that their artificial turf products (the “Products”) contain lead, and that use of, and contact with, those Products results in exposure to lead, a chemical known to the State of California to cause cancer and reproductive harm. The Complaint further alleges that under the Safe Drinking Water and Toxic Enforcement Act of 1986, Health and Safety Code section 25249.6, also known as “Proposition 65,” businesses must provide persons with a “clear and reasonable warning” before exposing individuals to these chemicals, and that the Defendants failed to do so. The Complaint also alleges that these acts constitute unlawful acts in violation of the Unfair Competition Law, pursuant to Business and Professions Code sections 17200 et seq. and 17500 et seq.
1.2 AstroTurf, LLC , Crystal Products Co., Inc. d/b/a SYNLawn, UGTH Equipment, LLC, General Sports Venue, LLC, and Synthetic Turf Resources, LLC (“Settling Defendants”) are among the Defendants named in the complaint.
1.3 Settling Defendants are alleged to be interrelated corporations that, separately and together, employ more than 10 persons and employed ten or more persons at all times relevant to the allegations of the complaint.
1.4 Settling Defendants manufacture, license, distribute and/or sell Products in the
State of California and/or have done so in the past four years.
1.5 For purposes of this Consent Judgment only, the People and the Settling Defendants stipulate that this Court has jurisdiction over the allegations of violations contained in the People’s Complaint and personal jurisdiction over Settling Defendants as to the acts alleged in the People’s Complaint, that venue is proper in Alameda County, and that this Court CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 2 1
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28 has jurisdiction to enter this Consent Judgment as a full and final resolution of all claims which were or could have been raised in the Complaint based on the facts alleged therein.
1.6 The People and Settling Defendants enter into this Consent Judgment as a full and final settlement of all claims relating to Covered Products (as that term is defined below) arising from the failure to warn regarding the presence of lead in such Products. By execution of this Consent Judgment and agreeing to provide the relief and remedies specified herein, Settling Defendants do not admit any violations of Proposition 65 or Business and Professions Code sections 17200 et seq. or 17500, et seq. or any other law or legal duty. Except as expressly set forth herein, nothing in this Consent Judgment shall prejudice, waive or impair any right, remedy, or defense the People and Settling Defendants may respectively have in any other or in future legal proceedings unrelated to these proceedings. However, this Paragraph shall not diminish or otherwise affect the obligations, responsibilities, and duties of the parties under this Consent Judgment, or the res judicata impacts of this Consent Judgment on other litigation brought under Proposition 65 or the Business and Professions Code.
2. DEFINITIONS
2.1 The “Effective Date” of this Consent Judgment shall be the date on which the
Consent Judgment is entered as a judgment by the trial Court (“Effective Date”).
2.2 Covered Products shall mean (a) the products listed in Exhibit A to this Consent Judgment and (b) any other artificial turf products that Settling Defendants may manufacture or sell after the Effective Date.
2.3 “Cushioning Products” shall mean any foam layering or other products that are
installed under the Covered Products but are not attached to the Covered Products by the
manufacturer.
2.4 “Infill Products” shall mean any granular product, including, without limitation, crumb, tire crumb, pellets, sand, or synthetic sand, that is installed under, on, or in connection with any Covered Product.
2.5 “Old Covered Products” shall mean Covered Products that were Sold In California before the Effective Date of this Judgment.
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28 2.6 “Sold in California” means any Covered Product that is sold in the State of California by Settling Defendants or by any, distributor, wholesaler or retailer that is authorized by Settling Defendants, to sell the Covered Products. For purposes of this Judgment, the date of sale shall be the later of the following: (a) the date of the sales contract; (b) the date that Settling Defendants transport or dispatch the Covered Product into California; (c) the date that Settling Defendants deliver, or cause the delivery of, the Covered Product to the installation site.
3. INJUNCTIVE RELIEF: LEAD REDUCTION
3.1 Immediate Product Reformulation. Immediately upon the Effective Date of this Consent Judgment, Settling Defendants shall reduce the level of lead in the Covered Products Sold in California from the current levels to a level no higher than 100 parts per million (“Compliance Level”) as determined pursuant to the testing protocol in Exhibit B.
3.2 Further reductions in lead levels in Covered Products. In addition to the requirements of Paragraph 3.1, and effective June 15, 2010, the Covered Products shall meet the following additional requirements (which shall be referred to as the “Further Compliance Level”):
(a) No portion of the Covered Product may have lead levels in excess of 50 parts per million, except:
(b) Field lines and markings (such as yard lines, goal lines and team names or logos) may not have lead levels in excess of 100 parts per million.
In the event that Settling Defendants’ Covered Products violate the Further Compliance Level, Settling Defendants will (i) consult with their suppliers and technical consultants; (ii) attempt to locate the source of the elevated lead seen the laboratory results; and (iii) provide the Plaintiffs with a report on this investigation and a proposal to prevent the situation from occurring in the future. On approval by the Attorney General, Se ttling Defendants will implement this proposal.
In the event that the Attorney General incurs laboratory costs in reviewing such a proposal, Settling Defendants will reimburse the Attorney General for reasonable laboratory costs actually incurred.
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28 4. INJUNCTIVE RELIEF: CLEAR AND REASONABLE WARNINGS
4.1 The People allege that warnings are necessary as to the Old Covered Products because these products cause continuing exposures to lead. Without admitting such allegations, Settling Defendants agree to implement the following program to provide clear and adequate warnings to persons who come into contact with turf products that were installed before the Effective Date of this Judgment.
(a) Settling Defendants shall provide the mailed warnings and informational materials attached hereto as Exhibit C, in English and Spanish, to all parties who purchased Old Covered Products for installation within the State of California on or after April 1, 2004 for Astro branded products and November 1, 2006 for the remaining Covered Products. Settling Defendants will send these mailed warnings within thirty days after receiving instructions to do so from the Attorney General. (b) Beginning thirty days after the Effective Date, and for a period of two years thereafter, Settling Defendants will establish a web site that complies with the provisions of Exhibit C, which shall provide the following information, in English and Spanish, about its products:
• Range of lead content for each Covered Product
• The date lead was phased out of each Covered Product • A warning informing consumers that the products in question contain lead, which is a chemical known to the State of California to cause cancer and reproductive harm.
• Proposition 65 and other regulatory levels applicable to lead in consumer products. • Links to specified sites
• Good maintenance practices to minimize lead transfer from Covered Products to consumers.
• Actions consumers can take to minimize lead transfer from Covered Products to consumers.
• Options for Lead Transfer Testing of Covered Products.
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28 The initial design and content of the website, and any later changes to the website will be subject to the advance approval of Plaintiffs, which shall not be unreasonably withheld.
If a trade association, a group of turf companies, or other responsible entities create a web site that is approved by Plaintiffs and satisfies the provisions of this Paragraph 4.1(b), Settling Defendants may comply with the terms of this Paragraph by placing a conspicuous link to that website on the websites maintained by AstroTurf and SYNLawn.
5. ADDITIONAL ACTIONS BY SETTLING DEFENDANTS
5.1 Plaintiffs have agreed to accept the settlement payment set forth in Section 5.2 -
5.4 below (Civil Penalties, Cy Pres, Other Payments) based on Settling Defendants’ commitment to take additional actions. Specifically, Settling Defendants shall do the following:
(1) Replacing Certain Old Covered Products. Settling Defendants shall replace any Old Covered Products in place as of the Effec tive Date and installed in the State of California after April 1, 2004 for Astro branded products and November 1, 2006 for the remaining Covered Products, if i. The Old Covered Product was (i) installed at a licensed day care facility, a school, a public playground, or a public playing field and (ii) has been in place for more than 3 years but not more than 8 years.
ii. the Lead Transfer Testing conducted pursuant to Exhibit D shows Available Lead Levels in excess of 0.1 micrograms per square centimeter;
iii. The owner or operator of the day care center, school, playground or playing field makes written request to AstroTurf that the field be replaced, and this request is received by AstroTurf no later than February 1, 2012. Se ttling Defendants shall not be CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 6 1
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28 required to honor any requests for replacement of Old Covered Product that are received after that date.
iv. The owner or operator shows proof of purchase and delivery of the Covered Product to the location at issue.
(2) Maximum Expenditure. Settling Defendants shal l not be required to provide more than 20,000 square yards of turf in order to comply with the provisions of this Section 5.1(1). Settli ng Defendants will mon itor the number of qualifying requests for replacement, and if it appears that this quantity of turf will prove insufficient to achieve full complia nce with those terms, Settling Defendants shall, after receiving written approval a nd direction from Plai ntiffs, pro-rate the remaining funds among the remaining claimants.
(3) Quality. The quality of the replacement turf that Settling Defendants provide pursuant to this section will be comparable to, or better than, the turf that is being replaced.
5.2 Civil Penalties. On or before June 1, 2010, Settling Defendants shall pay a civil penalty of $ 17,500 pursuant to California Health & Safety Code §§ 25249.7(b) and 25249.12.
Pursuant to section 25249.12, 75% of these funds shall be remitted to the California Office of Environmental Health Hazard Assessment (“OEHHA”), and the remaining 25% apportioned evenly among the Attorney General, the Los Angeles City Attorney, and the Solano County District Attorney.
5.3 Cy Pres. Settling Defendants shall make th e following payments in lieu of
penalties:
(a) Settling Defendants shall pay $ 60,000 to the California Public Health Trust. $40,000 shall be paid within 30 days of the Effective Date and $20,000 shall be paid on or before February 15, 2010. These funds shall be us ed, as the Trust directs after conferring with Plaintiffs, for some or all of the following:
(1) To fund independent testing, wh ich shall be conducted pursuant to CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 7 1
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28 the protocol attached as Exhibit D (L ead Transfer Testing), of Old Covered Products currently installed and in place at licensed day care centers, schools, and public playing fields in California; and to fund efforts to promote consistent testing of Old Covered Products throughout California.
(2) For research into Good Mainte nance Practices, including the feasibility of applying stabilizers to Ol d Covered Products in order minimize lead transfer from those products.
(3) To provide funding for an independe nt consultant, who will provide information to schools, municipalities and other locations in California where Old Covered Products are installed, rega rding independent testing and Good Maintenance Practices for such products.
(4) For other projects or grants fo r the purposes of reducing, or educating the public about, lead in consumer products.
(5) Any process undertaken by the Public Health Trust to identify and choose the entity(ies) that will receive any grant to be awarded under this Judgment must be open to public scrutiny and subj ect to public notice and comment. Any use of funds must be approved by the Attorney General.
(6) In order to minimize any duplicati on of effort, the Public Health Trust will coordinate the expenditure of funds received pursuant to this Judgment with any expenditures made pursuant to (i) judgments with other defendants in this case and (ii) judgments in other cases in which the Attorney General has alleged that lead in present in consumer products.
(b) On or before October 1, 2009, Sett ling Defendants shall pay $30,000 to the Office of Environmental Health Hazard Asse ssment (OEHHA), to be deposited into OEHHA’ Proposition 65 Fund, to be used, on appr opriation of the Legislature, to fund to fund a study or studies relating to potentially haza rdous chemicals in Infill Products.
OEHHA shall coordinate these studies with st udies that it may conduct pursuant to SB 1277 (Maldonado).
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28 5.4 Other Payments. Settling Defendants shall also make the following payments:
(a) Attorney General. On or before June 1, 2010, Defendant shall pay the sum of $17,500 to the Attorney General, to reimburse the fees and costs his office has expended with respect to this matter. Funds paid pursuant to this paragraph shall be placed in an interest-bearing Special Deposit Fund established by the Attorney General. These funds, including any interest, shall be used by the Attorney General, until all funds are exhausted, for the costs and expenses associated with the enforcement and implementation of Proposition 65, including investigations, enforcement actions, other litigation or activities as determined by the Attorney General to be reasonably necessary to carry out his duties and authority under Proposition 65. Such funding may be used for the costs of the Attorney General’s investigation, filing fees and other court costs, payment to expert witnesses and technical consultants, purchase of equipment, travel, purchase of written materials, laboratory testing, sample collection, or any other cost associated with the Attorney General’s duties or authority under Proposition 65. Funding placed in the Special Deposit Fund pursuant to this paragraph, and any interest derived therefrom, shall solely and exclusively augment the budget of the Attorney General’s Office and in no manner shall supplant or cause any reduction of any portion of the Attorney General’s budget. (b) City Attorney and Solano County District Attorney. On or before June 1, 2010, Settling Defendants shall make payments of $ 10,000 to the Los Angeles City Attorney and $ 10,000 to the Solano County District Attorney to defray the attorneys’ fees and costs these offices have expended with respect to this matter.
(c) Center for Environmental Health/Other Private Parties. Within thirty days of the Effective Date, and pursuant to Health & Safety Code section 25249.7(j), Settling Defendants shall pay $25,000 to the Center for Environmental Health and Lexington Law Group.
These payments represent full compensation from the Settling Defendants for (i) the assistance that CEH has provided to the Plaintiffs and (ii) the fees and costs that CEH has incurred with respect to this matter.
5.5 Each payment required by this Consent Judgment shall be made through the
delivery of separate checks payable to the applicable person, as follows:
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28 (a) Attorney General. Payments due to the Attorney General shall be made payable to the “California Department of Justice,” and sent to the attention of Robert Thomas, Legal Analyst, Department of Justice, 1515 Clay Street, 20th Floor, Oakland, CA 94612. (b) City Attorney. Payments due to the City Atto rney shall be made payable to the “Office of the Los Angeles City Attorney” and sent to: Patty Bilgin, Supervising Attorney, Environmental Justice Unit, Office of the Los Angeles City Attorney 200 North Main Street, 500 City Hall East, Los Angeles, California 90012-4131
(c) Solano County District Attorney. Payments due to the Solano County District Attorney shall be made payable to the “Office of the Solano County District Attorney” and sent to Criselda B. Gonzalez, Senior Deputy District Attorney, Office of the Solano County District Attorney, 675 Texas Street, 4th Floor, Suite 4500, Fairfield CA 94533-6396. (d) Office of Environmental Health Hazard Assessment. Payments due to the OEHHA shall be made payable to the Office of Environmental Health Hazard Assessment and sent to: Beverly Sloan, Senior Accounting Officer, Office of Environmental Health Hazard Assessment, P.O. Box 4010, Sacramento, CA 95812-0410.
(e) Center for Environmental Health/Lexington Law Group. The payment due to the Center for Environmental Health shall be made payable to the Lexington Law Group and sent to: Mark N. Todzo, Lexington Law Group, LLP, 1627 Irving Street, San Francisco, CA 94122
(f) Copies of checks. Settling Defendants will cause copies of each and every check issued pursuant to this Judgment to be se nt to: Dennis A. Ragen, Deputy Attorney General, 110 West A. Street, Suite 1100, San Diego, California 92101 (g) Late Payment/Acceleration. If any payment required by Sections 5.2, 5.3 or 5.4 of this Judgment is not received by the due date, then Plaintiffs will provide Settling Defendants ten (10) days’ notice of default. If Settling Defendants fails to cure the default within said ten (10) days, then at the option of the Attorney General, all unpaid balances due pursuant to those sections shall be accelerated, and shall become immediately due and payable, with interest thereon as specified in section 685.010 of the Code of Civil Procedure, commencing to accrue 10 CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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on the entire remaining unpaid balance of any sum pursuant those sections, as of the first day immediately after the ten-day delinquency that preceded the notice of default. Code of Civil Procedure section 1013, and the extensions provided for therein, shall not apply to nor extend any deadline referred to in this paragraph or in Sections 5.2, 5.3 and 5.4 of this Judgment. If the Attorney General declines to exercise and waives this optional acceleration as to any one or more default(s) in payment, said waiver or waivers shall not constitute a waiver of this option in the event of any other default. Defendants are pe rmitted at their option to pre-pay any time the remaining unpaid balance of any amount due in this judgment.
6. MODIFICATION OF CONSENT JUDGMENT
6.1 This Consent Judgment may be modified from time to time by express written
agreement of the Parties with the approval of the Court; by an order of this Court on noticed
motion from Plaintiffs or Defendant in accordance with law, for good cause shown; or by the
Court in accordance with its inherent authority to modify its own judgments.
6.2 Before filing an application with the Court for a modification to this Consent Judgment, the party seeking modification shall meet and confer with the other party to determine whether the modification may be achieved by consent. If a proposed modification is agreed upon, then Settling Defendants and the Attorney General will present the modification to the Court by means of a stipulated modification to the Consent Judgment.
7. ENFORCEMENT
7.1 Plaintiffs may, by motion or application for an order to show cause before this Court, enforce the terms and conditions contained in this Consent Judgment. In any such proceeding, Plaintiffs may seek whatever fines, costs, penalties, or remedies are provided by law for failure to comply with the Consent Judgment and where said violations of this Consent Judgment constitute subsequent violations of Proposition 65 or other laws independent of the Consent Judgment and/or those alleged in the Complaint, the Plaintiffs are not limited to enforcement of the Consent Judgment, but may seek in another action whatever fines, costs, penalties, or remedies are provided for by law for failure to comply with Proposition 65 or other laws. In any action brought by Plaintiffs or another enforcer alleging subsequent violations of CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 11 1
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28 Proposition 65 or other laws, Settling Defendants may assert any and all defenses that are
available, including the res judicata or collateral estoppel effect of this Consent Judgment.
8. AUTHORITY TO STIPULATE TO CONSENT JUDGMENT
8.1 Each signatory to this Consent Judgment certifies that he or she is fully authorized by the party he or she represents to stipulate to this Consent Judgment and to enter into and execute the Consent Judgment on behalf of the party represented and legally to bind that party.
9. CLAIMS COVERED
9.1 Full and Binding Resolution. This Consent Judgment is a full, final, and binding resolution between the People and Settling Defendants, of any violation of Proposition 65., Business & Professions Code sections 17200 et seq. and 17500, et seq. or any other statutory or common law claims that have been or could have been asserted in the Complaint against Settling Defendants for failure to provide clear and reasonable warnings of exposure to lead from the use of the Covered Products, or any other claim based on the facts or conduct alleged in the Complaint, whether based on actions committed by Settling Defendants or by any entity to whom Settling Defendants distribute or sells Covered Products, or any entity that sells the Covered Products to consumers. Compliance with the terms of this Consent Judgment resolves any issue now, in the past, and in the future, concerning compliance by any Settling Defendant, its parents, shareholders, divisions, subdivisions, subsidiaries, sister companies, affiliates, franchisees, cooperative members, and licensees; its distributors, wholesalers, and retailers who sell Covered Products; and the predecessors, successors, and assigns of any of them, with the requirements of Proposition 65 or Business and Professions Code sections 17200 et seq. and 17500 et seq. arising from exposures to lead in or from the Covered Products. This Consent Judgment does not resolve any claims that Plaintiffs may assert with respect to (i) products other than the Covered Products, or (ii) chemicals other than lead.
9.2 Covered Entities. Settling Defendants unconditiona lly guarantee that each other Settling Defendant will fully comply with the applicable provisions of this Consent Judgment, including the provisions of Sections 3 (Injunctive Relief: Lead Reduction) and 4 (Injunctive Relief: Clear and Reasonable Warnings), and the applicable provisions of Section 5 CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 12 1
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28 (Additional Actions by Settling Defendants). If any such company fails to so comply with the applicable provisions of this Consent Judgment, then in addition to Plaintiffs’ other remedies, Plaintiffs reserve the right to bring action, seeking penalties, injunctive and other relief, directly against such company to redress that company’s non-compliance.
9.3 Further Reservations: Without limiting the rights reserved to Plaintiffs in the
preceding paragraphs, Plaintiffs also reserve the right to bring actions, seeking penalties,
injunctive and other relief, against the following persons:
(a) Downstream Sellers. Distributors, whol esalers, and/or re tailers who, after the Effective Date of this J udgment: (i) sell Covered Products th at contain lead levels in excess of the applicable levels set forth in Secton 2.1 of this Judgment (Injunctive Relief:
Lead Reduction), or (ii) otherwise fail to comp ly with, or impede the efforts of others to comply with, the applicable terms of this Consent Judgment; and (b) Undisclosed Affiliates. Any affiliate or subsidiary of Settling Defendants that is not bound by the terms of this Consent Judgment. (c) Not Applicable to Cushioning and Infill Products . This Consent Judgment does not apply to any Cushioning Products or In fill Products. Plaintiffs expressly reserve the right to bring claims against Settling Defe ndants or any distributors, wholesalers, or retailers of Cushioning Products or Infill Products, for any vi olation of Proposition 65, the Unfair Competition Law or any other applicab le law or regulation, arising from the sale, use of, or exposure to any Cushioning Products or Infill Products.
10. ONGOING INVESTIGATION
10.1 Plaintiffs are conducting an ongoing investigation of lead and other chemicals in artificial turf and related products sold by companies other than Settling Defendants. In connection with this investigation, Settling Defendants will, upon reasonable notice, provide plaintiff with information, product samples, and other information and materials within their possession, custody or control, or that are readily available to them, relevant to such investigation, except to the extent that such information is privileged or otherwise protected from disclosure.
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28 11. PROVISION OF NOTICE
11.1 When any party is entitled to receive any notice under this Consent Judgment, the notice shall be sent to the person and address set forth in this Paragraph. Any party may modify the person and address to whom the notice is to be sent by sending each other party notice by certified mail, return receipt requested. Said change shall take effect for any notice mailed at least five days after the date the return receipt is signed by the party receiving the change.
11.2 Notices shall be sent by e-mail and by First Class Mail or overnight delivery to the following when required:
For the Attorney General:
Dennis A. Ragen, Deputy Attorney General
California Department of Justice
110 West A. Street, Suite 1100
San Diego, CA 92101
and simultaneously to:
Robert Thomas, Legal Analyst,
Department of Justice,
1515 Clay Street, 20th Floor,
Oakland, CA 94612
For the Los Angeles City Attorney
Patty Bilgin, Supervising Attorney, Environmental Justice Unit Office of the Los Angeles City Attorney
200 North Main Street, 500 City Hall East
Los Angeles, California 90012-4131
For the Solano County District Attorney
Criselda B. Gonzalez
Senior Deputy District Attorney
Office of the Solano County District Attorney
675 Texas Street, 4th Floor, Suite 4500
Fairfield CA 94533-6396
[email protected]
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28 For the Center for Environmental Health
Mark N. Todzo
Lexington Law Group, LLP
1627 Irving Street
San Francisco, CA 94122
11.3 Notices for the Settling Defendants shall be sent to:
Joann Brown Williams
General Counsel
2680 Lakeland Road
Dalton, Georgia 30721
(706) 876-5556
11.4 Written Certification. Within 15 days of any completing any action required by this Consent Judgment, and also on Plaintiffs’ written request, Settling Defendants will provide Plaintiffs with written certification that the required action has been completed.
12. COURT APPROVAL
12.1 This Consent Judgment shall be submitted to the Court for entry by noticed motion or as otherwise may be required or permitted by the Court. If this Consent Judgment is not approved by the Court, it shall be of no force or effect and may not be used by the Plaintiffs or Settling Defendants for any purpose.
13. ENTIRE AGREEMENT
13.1 This Consent Judgment contains the sole and entire agreement and understanding of the Parties with respect to the entire subject matter hereof, and any and all prior discussions, negotiations, commitments and understandings related hereto. No representations, oral or otherwise, express or implied, other than those contained herein have been made by any Party hereto. No other agreements not specifically referred to herein, oral or otherwise, shall be deemed to exist or to bind any of the Parties.
14. RETENTION OF JURISDICTION
14.1 This Court shall retain jurisdiction of this matter to implement and enforce the Consent Judgment, and to resolve any disputes that may arise as to the implementation of this Judgment.
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16 CONSENT JUDGMENT AS TO DEFENo.A.NT ASTRQTIJRF - Case No. RG 08407310 1 2
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15. EXECUTION IN COUNTERPARTS
15.1 The stipulations to this Consent Judgment may be executed in counterparts and by means of facsimile, which taken together shall be deemed to constitute one document.
IT 1S SO ORDERED and ADJUDGED:
DATED: _
JUDGE OF THE SUPERIOR COURT
IT IS SO ST1PULATED:
DATED: August_, 2009 EDMUND G. BROWN, JR.
Attorney General
J. MATTHEW RODRIQUEZ
Chief Assistant Attorney General
KEN ALEX
Senior Assistant Attorney General
EDWARD G. WElL
Supervising Deputy Attorney General
DATED: August_, 2009
DATED: August /3,2009 DAVID W. PAULSON,
District Attorney of Solano County
BY:C~:;.·G~Jf"-=------
Deputy District Attorney
By:=D-=E::-:NN::-::::IS,-A:-.-=RA:-:-:G=E=-N:--------- Deputy Attorney General
For Plaintiffs People of the State of California
CARMEN A. TRUTANICH
Los Angeles City Attorney
EARL E. THOMAS,
Chief of Criminal and Special Litigation
ELISE A. RUDEN
Deputy City Attorney
VAUGHN MINASSIAN
Deputy City Attorney
By:=PA:-TT=yc:-=B=IL--:G=IN:-:---------
Assistant City Attorney,
Environmental Justice Unit
CONSENT JUOGMENT AS TO DEFENDANT ASTROTURF - Case No. RG 08407310 16 1
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28 DATED: August 1::', 2009 ASTR0=::u.
By: zq.
Its: +>R-es:tk,t
DATED: August 13, 2009 CRYSTAL PRODUCTS CO., INC.
d/b/a SYNLAWN
By:q-Q<=
Its: ?ft<::Scd(Qt _
DATED: August 13,2009 UGTHEQUlP~C
By: . ~0\t\ ~~
Its: ill ,M ~£I'Z,
DATED: August J2, 2009 SYNTHETIC TUR.(RrSOURC.ES, LLC
. By: 0dM .Y'"ll ff .
Its: p'u,:.j dfvJt . ..
DATED: August \.3,2009
By: -b""£-~~~~....."..---,..-
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CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF - Case No. RG 08407310 17 1
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28 Exhibit A
Covered Products
A 1 – AstroTurf Styles sold into California
A 2 - Crystal Styles sold into California
A 3 - SYNLawn Styles sold into California
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 18 AstroTurf Styles Sold Into California
5/2004 ‐ 7/2009
4212 P0001
A0001 P3038
A5513 PB03
AT38 PF01
BCB10 PG32
BL10 RP02
CC2 RP04
DB40 RP07
E120T RTT01
E200 SD01
E360 SPG1
E500 SPG2
E610H SR01
E620H SR21
E640H ST65
E740 TELN
E750 TMINV
E840H TPN
E840T WG1
E955H WG2
ET100
FSF3
G130
G220
G2625
G3225
G4019
GC42
GDXPE
GM48
GXD32
LAN43
LL1
LS01
LS05
LS06
LS21
LSX3
LX60
MG1
MG2
MG3
NGC42
NGC52
Exhibit A‐ 1
19 Crystal Styles Sold Into California
2000 ‐ 2009
Bermuda I E820
Bermuda II E830
C1000 E840
C2000 E955H
C3000 FSF3
C4000 G110
C5000 G120
Concepts G130
Designer Choice G410
Duro Turf G430
Heather Point G450
Legend GM48
Leisure Turf LS01
Marine Carpet LS02
Master Turf LS03
Natural Weave LS21
Palace Gates LS31
Precepts LSX1
ST18 LSX2
ST24 LSX3
ST48 PE40
Turflawn PE50
ST35 PF01
PS100
AT26 PS400
AT38 PS700
E100 RP01
E200 RP02
E300 RP03
E355 RP04
E360 RP06
E400 RP07
E500 SPFT
E550 SW38
E610 TL100
E620 TL120
E630 TL80
E640 TP28
E710 TP38
E730 TP40
E740 TP41
E750 TP42
E800 TP50
E810 Exhibit A‐2 20
SYNLawn Styles Sold Into California
11/2006 ‐ 7/2009
BG28 basix by synlawn 28
BG30 basix by synlawn 30
BL10 basix by synlawn 10
BL100 basix by synlawn 100
BL20 basix by synlawn 20
BL30 basix by synlawn 30
BL40 basix by synlawn 40
BL60 basix by synlawn 60
BL70 basix by synlawn 70
BL80 basix by synlawn 80
SA100 SYNAugustine 100
SA130 SYNAugustine 130
SA140 SYNAugustine 140
SA230 SYNAugustine 230
SA240 SYNAugustine 240
SA330 SYNAugustine 330
SA340 SYNAugustine 340
SB100 SYNBlue 100
SB200 SYNBlue 200
SC100 SYNFringe 100
SC200 SYNFringe 200
SC210 SYNFringe 210
SD200 SYNBermuda 200
SD210 SYNBermuda 210
SD300 SYNBermuda 300
SD310 SYNBermuda 310
SF100 SYNFescue 100
SF110 SYNFescue 110
SF120 SYNFescue 120
SF214 SYNFesuce 214
SF220 SYNFescue 220
SF222 SYNFescue 222
SF310 SYNFescue 310
SF320 SYNFescue 320
SF340 SYNFescue 340
SF355 SYNFescue 355
SG100 SYNGreen 100
SG110 SYNGreen 110
SG134 SYNGreen 134
SG138 SYNGreen 138
SG150 SYNGreen 150
SG200 SYNGreen 200
SG300 SYNGreen 300
SG320 SYNGreen 320
SG322 SYNGreen 322
SG324 SYNGreen 324
SM110 SYNMarathon 110
SM112 SYNMarathon 112
SM114 SYNMarathon 114
SM120 SYNMarathon 120
SM130 SYNMarathon 130
SM210 SYNMarathon 210
SM220 SYNMarathon 220
SM222 SYNMarathon 222
SM230 SYNMarthon 230
SM240 SYNMarathon 240
SM310 SYNMarathon 310
SM312 SYNMarathon 312
SM320 SYNMarathon 320
SM330 SYNMarathon 330
SM355 SYNMarathon 355
SP300 SYNPlay 300
SP320 SYNPlay 320
SR100 SYNRye 100
SR200 SYNRye 200
SS300 SYNSod 300
ST100 SYNTipede 100
ST110 SYNTipede 110
ST120 SYNTipede 120
ST200 SYNTipede 200
ST220 SYNTIpede 220
ST320 SYNTipede 320
Exhibit A‐3
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28 Exhibit B
Testing Protocol for Use in Determining Lead Levels
1. Testing Protocol for Use in Determining Available Lead in Wipe Samples.
Each wipe will be prepared for analysis by acid digestion in accordance with EPA Method 3050B. The digestate will be analyzed using ICP spectrometry in accordance with EPA Method 6010c or alternatively EPA Method 6020A.
2. Testing of Turf:
If turf is tested pursuant to Section 3.1 of this judgment, sample preparation and analysis will be in accordance with EPA Method 3050B. The digestate will be analyzed using ICP spectrometry in accordance with EPA Method 6010c or alternatively EPA Method 6020A.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 22 1
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28 Exhibit C
Dear Customer:
Our records show that you purchased [AstroTurf, SYNLawn] products during the past __ years. This letter is writte n to inform you that certain [AstroTurf, SYNLawn] products contain lead. Specifically, the following Astroturf products contained lead at levels in excess of 100 parts per million (ppm):
[List Products]
WARNING – The artificial turf products listed above contain lead, which is a chemical known to the state of California to cause cancer and reproductive harm.
Lead was phased out of these products on the following dates:
Product D a t e
[Insert Product Name and Dates]
The following products have never contained lead in excess of 100 ppm. [Insert Product Names]
Good maintenance practices can reduce exposures to lead from these products. These practices include the following:
a. Keeping turf fields well-maintained and groomed and reducing surface dust and particles that could be ingested
b. Students and players should wash their hands after playing on a field. c. Food, beverages and other ingestible items should not be allowed on the field d. Equipment and clothing used when playing on the turf should be cleaned after use.
For other information about this issue, please check the following links:
A program for testing exposures from turf products that are installed at day care facilities, schools, public playgrounds, and public playing fields is now being administered by [Text to be provided by Attorney General]. In order to participate in program, please contact:
[Text and further detail as to the program to be provided by the Attorney General.] [Settling Defendants will consult with the Attorney General prior to finalizing the inserts to this letter.]
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 23 1
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28 Exhibit D
Lead Transfer Testing
Lead Transfer Testing shall be conducted as follows:
Materials
The materials used for sampling shall be lead free
1. Wipes
Premoistened GhostWipestm 15x15 cm
2. Delineations of area to be sampled
A cleanable template composed of thin plastic or metal, with inner dimensions of the 10x50 cm rectangular area to be wiped.
Alternatively, masking tape and measuring tape will be used to delineate the 10x50 rectangular area to be wiped. The distance between the perimeter of the inner and outer rectangles of the template or masking tape should be at least 5 cm.
4. Gloves
Disposable; plastic or rubber.
5. Sealable plastic bags, marker pen
Sampling Locations
Divide the total artificial turf area into 5 contiguous sections of equal areas.
This can be done by calculating the total area, dividing by 5 to determine the area of each sampling location and then marking off the area to be sampled.
Three sampling locations should be in the center of their respectively marked sections. Two sampling locations should be near the perimeter of the field in their respectively marked sections.
Illustrations with various geometries are given in Attachment D-1.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 24 1
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28 Plastic weights, chalk or string can be used to mark sample area boundaries. A measuring wheel, chain, laser tape rule, or conventional tape rule may be helpful, especially with complex geometries that might be found in a landscape application.
Sampling
For each field set of samples, there will be a total of 7 bags: five bags with one wipe in each bag, plus two bags with one blank wipe each.
1. Locate and delineate the areas to be wiped.
2. Wearing a new pair of gloves, remove a new wipe from its packaging and unfold it to its full dimensions.
3. A total of 5 strokes are made over the 10x50 cm area.
Firmly and evenly press across the width of the wipe during sampling.
Each stroke will start at one end and proceed to the other end of the 50 cm length.
Wipe with 2 linear strokes over the 50 cm length of the delineated area in the same direction.
Fold the wipe with the exposed side in, orient the wipe with the 15 cm crease at the leading edge, and wipe with 3 linear strokes over the 50 cm length of the delineated area in the other direction.
4. Refold the wipe with the exposed sides in to form a square, and place it in a new plastic bag. Seal and label the bag.
5. Discard the gloves. Clean the temp late if one was used. Discard the masking tape, if used.
6. For each field set of samples, the sampling method blanks shall consist of two unused wipes with packaging removed, each in an individual bag. If the amount of Pb in a blank wipe does not reasonably closely match its paired mate, or if both blank wipes are above an expected background level, the sampling for that field set must be redone on areas not previously wiped.
Lab Analysis
Lab Analysis will conducted according to Exhibit B - 1
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 25 1
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28 Calculations
Assuming the results for the two blank wipes for the field set meet the conditions in Sampling 6, average the two results.
The lead per square centimeter per stroke for each section of a field is represented by
(ug lead on a wipe - average ug lead on the blank wipes for that field set) / (500cm
2 * 5 strokes) = ug lead /cm 2 /stroke
The average (mean) for the field of artificial turf is the sum of the ug lead /cm2 / stroke result for each of the 5 sections, divided by 5.
Consultation
The contractor selected to perform Lead Transfer Testing pursuant to this Judgment may provide additional written instructions to the personnel who will be conducting the Lead Transfer Testing. This contractor shall meet and confer with representatives selected by Plaintiffs and Settling Defendant prior to initiating the first round of testing.
The resulting lead levels shall be deemed to be the Available Lead Level pursuant to this Judgment. These procedures and methods are meant only for use in this Judgment as a method of determining when removal of an existing field is appropriate. They have not been approved by the Plaintiffs or Settling Defendants as appropriate for making exposure calculations or estimates pursuant to Health and Safety Code section 25249.6 et seq. or any other law or regulation. CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310 26 1
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Attachment D-l
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF - Case No. RG 08407310 - August 11, 2009
27 From: Leanne McAuliffe
To: Council, City
Subject: Meeting Nov 17, Action Item 9: Approval of the Study and Assessment of Turf Systems - Public Comment with addition
Date: Friday, November 14, 2025 2:40:44 PM
Attachments: TTT pg1.png
TTT pg 2.png
TTT pg 3.png
TTT pg 4.png
TTT pg 5.png
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear City Council Members,
For clarity, the below email sent on Nov 12 is a public comment is for the PA City Council meeting on November 17, Action Item 9.
And a follow on note to that email:
The referenced Industry Tactics page mentions Gradient and it's worth noting that appendix E of the turf study shows that Field Turf is using the firm Gradient to defend itself to the City of Palo Alto and that The Center for Public Integrity describes Gradient as belonging to "a breed of scientific consulting firms that defends the products of its corporate clients beyond credulity, even exhaustively studied substances whose dangers are not in doubt, such as asbestos, lead and arsenic." The scientists who defend these products have been dubbed "rented white coats." https://publicintegrity.org/environment/meet-the-rented-white-coats-who-defend-toxic-chemicals/ Sent: 12 November 2025 19:41
To: [email protected] <[email protected]> Subject: Action Item 9: Approval of the Study and Assessment of Turf Systems -
Dear Palo Alto City Council Members,
Please take a few minutes to read the information in the link below regarding Industry Tactics (Test the Turf Collaborative, 2025). This should help you understand the sheer frustration of community members trying to educate and advocate for natural grass fields.
Community members are desperate to get good sports fields for our kids and many have This message needs your attention
This is a personal email address.
Mark Safe Report
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shared a plethora of information as to why natural turf is a holistically safer option than plastic turf. (Safer for the health of kids, the environment and public funds.) Since El Camino is already plastic, is the horse already out of the barn? Yes. But that doesn't mean the decision can't be made to revert fields back to natural turf (which can take substantially less than 18 months!) and stop any further damage.
Over the past 5 years of following and researching the topic of artificial turf I have seen industry narrative morph from 1
st Dog Defense (no harm) to 2nd Dog Defense (no risk) to 3rd Dog Defense (low risk) within our county, state and nationally. I then came to the unfortunate realization that grass advocates and independent experts have in fact done the plastic turf industry a huge favour because we have shared so much well researched, documented and referenced information with decision makers (like you) that if industry has to play the 4
th Dog Defense (you knew) card then no one supporting or approving the installation of plastic turf will be able to say they didn't know the risks. So can we please just stop the madness now BEFORE industry needs to play the 4
th Dog Defense card.
Don't approve the report in its current form.
Take the time to understand and acknowledge the risks of plastic fields as documented by independent experts and have these incorporated into the report.
Consult independent Certified Sports Field Managers experienced in well designed, installed and organically managed natural turf sports fields and have this information incorporated into the report.
Approve conversion from plastic sports fields back to natural turf.
Take the multiple millions that would have gone into plastic fields and instead invest it in properly maintaining natural turf fields. (Invest in our kids health, local jobs, and the environment and not the profit driven multibillion dollar plastic industry.) We can't change the beginning, but we can stop where we are and change the ending.
Kind regards,
Leanne McAuliffe
Santa Clara County resident
https://www.testtheturf.org/industry-tactics.html
NB: In the event that the link doesn't work I've attached screen shots of this web page. (labled TTT pages 1-5)
From: Andrea Wald
To: Council, City
Subject: Mtg. 11/17/25 - Agenda item #9: Approval of the Study and Assessment of Turf Systems Date: Thursday, November 13, 2025 3:21:51 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Mayor and Council members,
There has already been a great deal of material provided to you that talks about the inconsistencies in the Lloyd Study and recommendations not to accept it. There has also been well researched/documented materials provided that highlight the harms of artificial turf and why it should not be installed in any of your city’s parks/athletic fields, residences, etc.
I’ve decided to take a different approach in my message today.
Are you aware of the 50 years it took concerned individuals to get action regarding cigarettes because they were worried about the exposure to the harmful smoke – warnings on packaging, bans to smoke in restaurants, office buildings, airports and on airplanes? Creating stricter rules for vendors of cigarettes about verifying the age of the individual purchasing cigarettes – since there has never been a law to simply outright ban them.
Well, the reason it took so long is because of the influence and associated wealth of the tobacco industry and their paid lobbyists. Those asked to look into regulations were unduly influenced by outsiders and did not take seriously enough all the harms of cigarette smoke – not only on those who choose to smoke but the general public that was exposed to the toxins – and not by their own choice.
Something extremely similar is happening with plastics in general – although for the purpose of my urgent plea – I’m talking about synthetic ground coverings: artificial turf and PIP – poured-in-place rubber. The manufacturers and vendors, the companies that are benefiting financially from a product that does not last and must be replaced, that has no regulations in place for monitoring it nor requirements to divulge the chemicals used in the manufacture process, no responsibility or accountability for what happens to it when it comes to its useful end of life are all trying to convince us of the safety of their product – and too many are believing them. What happened to common sense and thinking that if there is any shred of doubt about the safety of a product that it should be avoided?
As elected officials it is your responsibility to protect those in your community and even beyond, since the impacts of unnecessary plastics, like artificial turf and PIP, do go beyond your city boundaries. Should all community members be expected to bear the burden of the toxins and microplastics associated with the artificial surfaces I’ve mentioned? And what about our youth? People do continue to smoke but for most of us, that means they are affecting only their own health – although we all bear the cost of expensive treatments for those who do come down with debilitating illnesses related to their smoking. As for artificial turf and PIP – our youth do not have a say in the toxins and microplastics we are exposing them to – with cumulative effects over years and harms/illnesses most times only appearing many years after exposure. The same holds true for This message needs your attention
This is a personal email address.
Mark Safe Report
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those of us who end up being exposed to the toxins and microplastics that are a result of wear on the artificial surfaces. Why should I suffer because of some perceived benefits to the small percentage of community members who claim they cannot live without soccer fields or playgrounds made from artificial materials? I know that most in the soccer world actually do prefer natural grass – especially if its maintained properly.
Its time to do the right thing and think about how change is possible and how we can all benefit by a healthier, more sustainable future. We should not burden future generations with possible health issues, cleaning up toxic messes, nor overflowing landfills.
Medical and environmental research is still ongoing and continually finding more and more reasons why we need less UNESSENTIAL plastics – including artificial ground covering.
Please do not approve the Lloyd study. Please strongly look into how you can provide the best organically managed, natural grass playing fields for all. A pilot program as recommended by both Lloyd’s and your own Parks and Rec commission is a step in the right direction. And why not make it El Camino park – rather than cover it with more toxic, plastic grass? I appreciate your considering all the ramifications of the decisions you make on Monday night and if at all not 100% sure you are doing the right thing, please delve a bit deeper into how to do what's best for your community as a whole and future generations and not just a smaller subset of sports teams.
Thank you.
Andrea Wald
From: Manny Diaz
To: Council, City
Subject: Turf Study
Date: Thursday, November 13, 2025 10:35:51 AM
Attachments: 11.13.25 - TenCate Letter to Palo Alto City Council.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Mayor and Council Members,
Attached is a letter from CEO Joe Fields of TenCate Grass regarding the turf study issue that you will discuss at your November 17, 2025 Palo Alto City Council meeting.
Thank you for your consideration.
Manny Diaz
Consultant for TenCate Grass
Manny Diaz & Associates inc.
This message needs your attention
This is a personal email address.
This is their first email to your company.
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November 13, 2025
Palo Alto City Council
City of Palo Alto City Hall
250 Hamilton Avenue
Palo Alto, California 94301
RE: Draft Study on Synthetic and Natural Turf Athletic Fields Honorable Mayor Ed Lauing, Councilmembers Patrick Burt, George Lu, Julie Lythcott-Haims, Keith Reckdahl, Greer Stone, Vicki Veenker
Thank you for your consideration and the thoughtful approach you’re taking in evaluating the best surfaces for Palo Alto's municipal park system. We appreciated the opportunity to speak with Lloyd Sports + Engineering as they prepare their study on synthetic and natural turf athletic fields.
In response to the publication of the draft report, we wanted to follow up and reiterate the immense value of artificial turf and the recent technological advances that ensure the health and safety of the athletes and communities that use synthetic turf, which the study included.
These are important factors that we hope the Commission will consider as the turf study process continues.
TenCate’s Leadership and Commitment to Safety and Sustainability
1. Established Track Record
TenCate Grass is the largest manufacturer, distributor, installer, and recycler of artificial turf in the United States —and a global industry leader. We recognize and respect the concerns surrounding artificial turf, and in response, we have devoted significant resources to developing more sustainable turf systems. Numerous independent studies and comprehensive research reviews have repeatedly demonstrated the safety of artificial turf. Our continued work reinforces these findings and ensures that our products meet or exceed health, safety, and environmental standards.
2. Advanced Turf Solutions & Research
Our latest innovations exemplify our dedication to safer and more environmentally friendly turf systems. Below are some key updates:
• PFAS-Free Since October 2023 : We proactively eliminated the use of PFAS in our turf manufacturing processes to address public health concerns. • No Performance Infill Required: Our newest turf, Pivot®, requires no sand or black crumb rubber. By removing traditional infill, primary microplastics pollution is eliminated and the surface can be 30–50 degrees cooler than turf systems using rubber and/or conventional abrasive materials.
• Equivalent Injury Rates: Independent studies by the NFL and NCAA demonstrate no difference in injury rates when comparing artificial turf to premier -quality natural grass stadium fields. Indeed, research shows that turf can be significantly safer than regularly used grass fields, such as those used by high schools and community parks. • Recyclability: Turf systems can be recycled. TenCate has a turf recycling center in Louisiana where we have processed a number of fields from California—including a field recently removed from Stanford University. In 2019, TenCate also led the way by establishing recycling capabilities in the Netherlands where now over 95 % of turf fields are recycled.
• Water Conservation: Artificial turf uses significantly less water than natural grass fields— an important factor in water-sensitive regions.
• Chemicals: Unlike natural grass fields, artificial turf fields do not require the use of any pesticides, fertilizers or herbicides (many of which contain PFAS or are classified as PFAS) – all of which contaminate the soil in and around natural grass fields and can find their way into our water.
• Increased Playability & Equity : Artificial turf dramatically increases playing availability compared to natural grass fields, enhancing community access.
Conclusion
We value the feedback from environmental and community groups and acknowledge the importance of ongoing engagement with all stakeholders. Thank you for the opportunity to share the facts about artificial turf and for the thoughtful approach the City of Pal o Alto has taken thus far. TenCate remains committed to working with you, your staff, and all stakeholders to ensure that residents benefit from the proven advantages of artificial turf while safeguarding public health and the environment.
Should you have any questions or wish to discuss these topics further, please feel free to contact us. We look forward to the opportunity for continued collaboration.
Thank you for your consideration.
Very sincerely,
Joe Fields
CEO Americas,
TenCate Grass
From: Magdalena Cabrera
To: Council, City; Lauing, Ed
Subject: Fwd: Nov 17 decision on Lloyd consulting findings Date: Thursday, November 13, 2025 7:04:30 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Esteemed council members and Mayor,
I write to you once again to urge you to consider very carefully the vote to accept or reject the findings of the Lloyd study on artificial turf. As the saying goes, buyer beware! There is Too much hard science out in the world that tells us that the toxic chemicals in artificial turf are abundant and dangerous to all living things. Nano and micro plastics abound in the environment, in your bodies and in mine.
There is NO place on earth without nano plastics in evidence. Think of that! NO place on earth.
In my humble opinion, there is no good reason to keep using artificial turf or PIP rubber. If we do a serious cost/benefit analysis, one that is deep and looks long term, I believe with all my heart that we will understand that the cost far exceeds the benefit.
Let us be the city of LIght and Good Sense. Let us lead the way and be the shining example of doing the right thing , inspiring other cities to follow our stellar example in protecting our citizens and the environment.
Vote no on the less than objective Lloyd study. Think about the warning In Dr Suess' The Lorax or in the Joni MItchell song "Big Yellow Taxi" we listened to when we were young: " Don't it always seem to go that you don't know what you've got till it's gone. Paved paradise, put up a parking lot." Respectfully,
Magdalena Cabrera
long time resident of the Ventura Neighborhood
PS: Thank you for the grass field at Boulware Park. The first effort at "meadow" was , as you know, not at all appealing or usable. This is a huge win for everyone.
PSS: Open the attachment if you are unfamiliar with the prescient lyric by Joni Mitchell. https://jonimitchell.com/music/song.cfm?id=13
More on nano plastics:
https://www.sciencedirect.com/science/article/pii/S2772416622000146 From: Sue
To: Council, City
Subject: Organically-Managed Natural Grass Field Pilot Project Date: Wednesday, November 12, 2025 10:03:57 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
!
Dear Mayor Lauing and Palo Alto City Council Members:
I am writing to urge you to support a pilot program to design, build, and maintain a high- quality organically managed grass field in Palo Alto. A most useful recommendation from the Lloyd study is to implement such a pilot project to demonstrate best practices and collect reliable data on performance, cost, and usability.
A well-designed pilot would allow Palo Alto to directly compare the costs and carrying capacity of a high-quality organic field, using drought-tolerant grasses and good surface drainage. In other regions, well-maintained organic fields have provided up to 2,000 hours of play per year—meeting community needs while eliminating pesticide use and synthetic turf waste.
El Camino Park would be an ideal location for this pilot. Planning could begin this year, with sod installation to shorten the timeline for completion. Its lighting would also allow extended play hours that most local grass fields do not currently offer. Choosing to move forward with a natural grass pilot—rather than installing more plastic turf—would reinforce Palo Alto’s reputation as an environmental leader and help avoid the documented harmful environmental and human health impacts of synthetic turf before, during, and after its life cycle.
The Lloyd study provides limited detail on pilot design. Based on successful examples elsewhere, the following elements are recommended:
Partner with the county, nearby cities, and the school district to share costs and data regionally.
Develop the plan with guidance from agronomists who have experience designing and maintaining successful organic grass fields. Beyond Pesticides and similar organizations will offer expert assistance at very low cost.
Avoid a sand-capped field. Instead, amend native soils with organic material and aerate regularly to provide internal drainage; ensure smooth surface grading and a slight crown for surface runoff.
Install high-efficiency irrigation, such as MP rotators, to mimic rainfall and reduce water This message could be suspicious
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use, drift, and puddling.
Select grass species known for durability and year-round usability, including warm- season grasses suited to California’s climate.
Use soil-building organic management practices that add carbon and nutrients while reducing runoff to storm drains.
Increase the maintenance budget and ensure strong accountability through detailed contracts. Require maintenance logs, photo documentation, and performance-based payments.
Include consistent gopher control and prompt repair of holes, ruts, and uneven areas caused by wear or animals.
Implement a simple online community reporting tool for issues such as gopher holes, irrigation malfunctions, or field condition concerns.
Use adaptive management to refine practices as field monitoring data are collected.
This pilot would provide valuable insights into long-term cost-efficiency, resilience, and community satisfaction while modeling environmentally responsible land management. I hope the Council will seize this opportunity to lead regionally in sustainable, safe, and high-quality athletic fields.
Thank you for considering this important initiative. I would be happy to share more examples or connect staff with experts in organic turf management.
Sincerely,
Sue Chow, City Resident
From: Leanne McAuliffe
To: Council, City
Subject: Action Item 9: Approval of the Study and Assessment of Turf Systems - Date: Wednesday, November 12, 2025 7:42:33 PM
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i
Dear Palo Alto City Council Members,
Please take a few minutes to read the information in the link below regarding Industry Tactics (Test the Turf Collaborative, 2025). This should help you understand the sheer frustration of community members trying to educate and advocate for natural grass fields.
Community members are desperate to get good sports fields for our kids and many have shared a plethora of information as to why natural turf is a holistically safer option than plastic turf. (Safer for the health of kids, the environment and public funds.) Since El Camino is already plastic, is the horse already out of the barn? Yes. But that doesn't mean the decision can't be made to revert fields back to natural turf (which can take substantially less than 18 months!) and stop any further damage.
Over the past 5 years of following and researching the topic of artificial turf I have seen industry narrative morph from 1
st Dog Defense (no harm) to 2nd Dog Defense (no risk) to 3rd Dog Defense (low risk) within our county, state and nationally. I then came to the unfortunate realization that grass advocates and independent experts have in fact done the plastic turf industry a huge favour because we have shared so much well researched, documented and referenced information with decision makers (like you) that if industry has to play the 4
th Dog Defense (you knew) card then no one supporting or approving the installation of plastic turf will be able to say they didn't know the risks. So can we please just stop the madness now BEFORE industry needs to play the 4
th Dog Defense card.
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Don't approve the report in its current form.
Take the time to understand and acknowledge the risks of plastic fields as documented by independent experts and have these incorporated into the report.
Consult independent Certified Sports Field Managers experienced in well designed, installed and organically managed natural turf sports fields and have this information incorporated into the report.
Approve conversion from plastic sports fields back to natural turf.
Take the multiple millions that would have gone into plastic fields and instead invest it in properly maintaining natural turf fields. (Invest in our kids health, local jobs, and the environment and not the profit driven multibillion dollar plastic industry.) We can't change the beginning, but we can stop where we are and change the ending.
Kind regards,
Leanne McAuliffe
Santa Clara County resident
https://www.testtheturf.org/industry-tactics.html
NB: In the event that the link doesn't work for public comments I've attached screen shots of this web page. (TTT pages 1-5)
From: Claire E
To: Council, City
Subject: November 17, 2025 Agenda Item #9, Approval of the Study and Assessment of Turf Systems Date: Wednesday, November 12, 2025 7:15:17 PM
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i
November 12, 2025
Dear Council Members,
Thank you for the opportunity to comment on Agenda Item #9, Approval of the Study and Assessment of Turf Systems. Unfortunately, the turf study by Lloyd Sports and Engineering, is not an unbiased assessment of the options and vital information is misleading or missing that is needed to select an appropriate turf system for any of Palo Alto’s parks.
I have detailed a number of concerns with the study. I believe that the right solution is to move quickly to instead and adopt the Lloyd study and staff recommendation to implement a natural grass pilot project, not at some point at some undisclosed location but as soon as possible, and at El Camino Park. Natural grass is healthier, provides more aesthetic appeal and ecological value, has a lower carbon footprint and can (if well designed and maintained) provide many more hours of use than the Lloyd study concludes.
Please consider my points listed below when reviewing the staff report and Lloyd study in preparation for the November 17th meeting.
Thank you!
Claire Elliott, Palo Alto resident
Points to consider for November 17
th:
1. The Lloyd study should not be approved in its current biased and This message needs your attention
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incomplete form: A large concern is the poor attention paid to the health impacts of synthetic turf.
b) The “Heath Hazards” section lists one chemical health hazard for synthetic grass (PFAS) and several for natural grass, even though the chemicals listed for natural grass are all pesticides that Lloyd must know Palo Alto does not use.
c) The report downplays the PFAS concern by saying the city can procure PFAS free turf.
d) This is a serious problem because it is not yet possible to confirm any product is PFAS free
e) A large number of PFAS compounds that could be incorporated into feed stocks used by the turf manufacturer and many of these compounds have no approved analytical method to identify their concentration in a material.
f) In addition, synthetic turf often contains a large number of compounds besides PFAS that are known to be toxins, carcinogens and endocrine disruptors.
g) Also, during its use, plastic grass blades often break off and then turn into microplastics which are known to have many negative health impacts and are being found in many parts of our bodies.
2. A second concern is uneven focus of environmental concerns for all three turf types evaluated by the study.
a) No mention of PFAS as an environmental contaminant is made, the only environmental concern listed for synthetic turf is the release of microplastics.
b) For hybrid and natural grass, carbon footprint and water use were described, but not for synthetic turf even though its carbon footprint is high and water is used in washing and cooling the turf. Sometimes antibacterial solutions are also used which can be released into the environment.
c) No other chemical releases from synthetic grass is mentioned (like health impacts they should have include the thousands of chemicals that may be included and leached out of synthetic turf, including many that are toxins, carcinogens and endocrine disruptors.
3. The cost figures are misleading in the final report. a) The cost per hour calculated for natural grass fields assumes these fields are only used for an average of 500 hours per year when the study itself lists nine grass fields in Palo Alto that are currently used over 1,000 hours per year.
b) The cost per hour for synthetic turf assumes El Camino was used for 2,700 hours per year. This calculation included some “double- dipping” because when the two halves of the field were used at the same time, two instead of one hour was used. The consultant admitted if this method is changed, the usage would be 1,900 instead of 2700 hours per year. It should be changed because the cost for installing and maintaining the fields is based on the full-sized field, not half of a field!
c) When you redo the cost estimate per hour of usage, these corrected numbers result in the cost per hour for grass changing from $179 to $89 and synthetic turf changing from $79 to $92. Showing natural grass can cost less per hour of play.
d) The cost for synthetic turf would go up further from $92/hour of play if you include the cost for recycling the turf which was left out of the study.
e) The cost for synthetic turf would go up even farther if the study included an estimated cost for the environmental and health impacts of synthetic turf during manufacture, use and disposal. f) In the October 28th Parks and Recreation meeting, the Lloyd consultant stated that recycling turf is expensive so the turf might be repurposed for batting cages, as substrate for horse arena soils or shipped south of the border. What is the eventual fate of these “repurposed” turf fields?
g) What is the economic impact of synthetic turf chemicals and microplastics in our soil and waterways, the cost to clean up contamination caused by reuse and disposal, or the price of medical bills and shortened life spans for those in plastics manufacturing industries who are known to have significantly higher cases of many diseases?
4. One recommendation of the Lloyd study that makes a lot of sense is to design and implement a pilot project of a well-designed and maintained grass field.
a) This would allow Palo Alto to gather data to compare costs and carrying capacity of a high-quality organic grass field with drought resistant grasses and good surface drainage. These types of fields have been shown in other parts of the country and world have provided up to 2,000 hours of use per year.
b) This pilot project would be ideally implemented now at El Camino Park. The design could start this year and by installing sod instead of seeding you could shorten the project timeline.
c) The lighted field at El Camino would also allow extended play many grass fields in Palo Alto do not offer.
d) Saying no to plastic grass and implementing a natural grass pilot project would help Palo Alto maintain a reputation as an environmental leader and avoid the well-known environmental and human health impacts of a synthetic field before, during, and after its useful life.
The Lloyd study gives little detail about what a pilot project design should include. Consider these details:
a) Partner where possible with the county, other cities in the region, school district, etc, so the costs and results can be shared regionally b) Develop the plan with expert help of agronomists who have already had success designing and maintaining organic grass fields.
Beyond pesticides may be able to provide some of this expert help at no or low cost to the city.
c) Save money and water and make organic management more successful by NOT using a sand capped field. Provide internal drainage by amending the native soils with organics, and aerating often. Provide surface drainage with careful grading that provides a smooth surface with a slight crown in the middle.
d) Include high efficiency irrigation (e.g. MP rotators) to mimic rainfall and reduce drift and puddling of water.
e) Selects a grass species that has been shown to allow additional play time (possibly a warm season grass that has been shown to work in California.)
f) Use organic management that adds carbon and nutrients that are less likely to runoff into stormdrains.
g) Grass field monitoring and maintenance is critical. Increase the budget for these necessities. Ensure contracts for maintenance are detailed, hold back funding to ensure the contractor performs well. h) Control gophers and fill holes and ruts caused by animals, people, vehicles, etc.
i) Ensure maintenance protocols are detailed in contracts and funding held aside until contractors prove they are following the required protocols. Ask for logs of maintenance and photo documentation of improvements made.
j) Develop an easy to access and use crowd sourcing method of evaluating field conditions (online tool for reporting gopher holes, irrigation problems leading to dry or soggy conditions, etc. k) Use adaptive management to alter practices as results from monitoring show improvements are needed.