Kenebrew, Jerice
From:
Sent:
To:
Subject:
Attachments:
cityclerk
Monday, May 13, 2024 6:45 PM
Iraheta, Alba; Jomsky, Mark; Rabies, Sandra; Sabha, Tamer; McMillan, Acquanette (Netta); Kenebrew, Jerice; Soo, Christine; hlaskett, John FW: MSC, 14 May 2024, Item 1; for the Public Record
Pasadena MSC 13 May 2024.pdf
From: D Woelke _ ^...„...„....
Sent: Monday, May 13, 2024 6:41:12 PM (UTC-08:00) Pacific Time (US & Canada) To: cityclerk <[email protected]>; Sabha, Tamer <[email protected]>; Stevenson, Garrett <[email protected]>
Subject: MSC, 14 May 2024, Item 1; for the Public Record Some people who received this message don't often get email from [email protected]. Learn why this is important ^\] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you frnowthe content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0010263" on the DolT portal.
Good evening:
Attached please find comments submitted for the public record. Please distribute electronically/via email so that Committee members can access the important embedded hyperlinks.
Thank you in advance,
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthvplavinflfields.orfl
SHPFI is an all-volunteer nonprofit 501-c-3
^SAFE WEALTHY^
PUYIM6FIELDS1";'rJBEYOND PLASTICS
*4 ILIATE
1 Safe Healthy Playing Fields Inc.
JS^SAFE HEALTHY,^
^S PLAYING FiELDS'£0-BEYOND PLASTICS
APFiLiAT^
www.safehealthvplavingfields.org
14 May 2024
Pasadena Municipal Services Committee - Item #1
Dear Committee Chair Williams, Council Members Hampton, Jones and Lyon:
Thank you for the opportunity to submit these comments on behalf of Safe Healthy Playing Fields, Inc(SHPFI).
SHFPI is an all-volunteer 501-c-3 non-profit. We are committed to educating communities, policy-makers and elected officials about the health, safety and financial realities of plastic fields versus grass fields and other synthetic surfaces for their parks and schools. Our constituency ranges from concerned individuals to community and civic organizations, legal, healthcare and science professionals, municipal leaders and state legislators.
SHPFI is in full support of a residential ban on synthetic turf in Pasadena as well for playing fields on city owned and leased land. Synthetic turf is plastic turf and is not consistent with Pasadena's commitment to environmental responsibility.
WORRIED ABOUT
PLASTIC WASTE?
A synthetic turf field is the equivalent of
^
^sas
3.2 million
plastic
bags
46 million
plastic
straws
Pasadena has:
2012
Plastic bag ordinance
effective
2014
Zero Waste Strategic Plan
2018
Climate Action Plan
2021
Single Use Plastic Ordinance
We would like to note that there are errors in the document submitted by the Director of Parks and Recreation and Community Services:
^ss^, i
^
^r^
Agenda Report
'r^(1
May 14,2024
TO; Municipal Services Commitiee
FROM; Parks, Recreation and Community Services Department SUBJECT: REVIEW OF SENATE BILL 678 RELATED TO ARTIFICIAL TURF ON
RESIDENTIAL PROPERTIES AND LOCATION OF ARTIFICIAL TURF
ATHLETIC FIELDS IN PASADENA
RECOMMENDATION;
Find the action proposed herein is not a project subject to the California" Environmenta! Quality Act ("CEQA") pursuant to CEQA Section 21065 and State CEQA Guidelines Sections 15060(c){2) and (c)(3). and 15376 of the Stale CEQA Guidelines; and
2. It is recommended that the Municipal Sen/ices Committee receive and file this I report on California Senate Bill (SB) 67G related to the cities authority to banartificial turf as an option for drought tolerant material on residential properties; or 3, Direct the Environmental Advisory Committee ll I 1 III liiill||,| i ilii ill SB 676 and provide recommendations for Council's consideration of ar residential properties,
BACKGROUND:
I On April 29, 2024, the City Council held a joint meeting wilh the Pasadena Unified School District Board. During the meeting, PUSD Board President Kimberly Kenne expressed concern about recent discussions on restricting artificial turf as an option far drought tolerant material and the potential impacts it may have on the District's maintenance and operations program. President Kenne further requested that discussions related to artificial turf be communicated with district staff. Also at the mooting, Councilmember Felicia Williams mentioned a discussion during a Municipal Services Committee (MSC) meeting wherein she requested staff to draft a report on Senate Bill (SB) 676 for MSC's consideration.
!:s-"~"ml—:l
MLLUMCi. C;^Gi^N^A i'.'FM NO .„.
•—1
.. J
1. California Environmental Quality Act - CEQA
This document cannot serve as a Notice Of Exemption and may be in violation of CEQA.
Synthetic turf is not exempt from CEQA, as it:
Cannot qualify for a CEQA categorical exemption due to significant environmental impacts that cannot be mitigated
Unusual circumstances
Cumulative effects exceptions apply
Cal. Pub. Res. Code § 21000(g):
"...all agencies of the state government which regulate activities of private individuals, corporations, and public agencies which are found to affect the quality of the environment, shall regulate such activities so that major consideration is given to preventing environmental damage, while providing a decent home and satisfying living environment for every Californian."
Cal. Pub. Res. Code § 21002:
CEQA mandates public agencies to disclose significant environmental effects of projects through preparation of an Environmental Impact Report ("EIR"). CEQA includes a substantive obligation of public agencies:
"...should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects."
Thus, CEQA's purpose is to "...assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects." CEQA is intended "...to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language." (Aptos Council v. County of Santa Cruz, 216 Cal. Rptr. 3d 142, 149 (Cal. Ct. App. 6th 2017) (quoting Laurel Heights Improvement Ass'n v. Regents ofUni. of Call., 47 Cal.3d 376, 390 (Cal. S.Ct. 1988).
Legislative and Regulatory Schemes:
An awareness of legislative and regulatory schemes is a requirement under Title 14. Natural Resources. Division 6. California Natural Resources Agency, Chapter 3. Guidelines for the Implementation of the California Environmental Quality Act [CEQA], Article 1. General §15004^ Time_of Preparation.
CA DTSC - regulation of PFAS as a chemical class at the PPQ (Parts Per Quadrillion) level CA DTSC - Microplastics, added to Priority Chemicals List CA DTSC - PFAS and other chemicals in synthetic turf (pg.14) CAStatewide Microplastics Strategy - Senate Bill No. 1263, Chapter 609, 2018 SB 903 - Environmental health: product safety: perfluoroalkyl and polyfluoroalkyl substances CA Coastal Commission - conditioned permit for UCSB Cesar Uyesaka Baseball for natural grass only, due to microplastic pollution concerns. No removal of trees was also conditioned in the permit.
Greenhouse Gas Emissions:
Cal. Code Regs. tit. 14 § 15064.4 (amendments effective 28 Dec 2018):
A good-faith effort, based to the extent possible on scientific and factual date, to describe, to:
(1) Quantify greenhouse gas emissions resulting from a project; and/or (2) Rely on a qualitative analysis or performance based standards ".. .public agencies shall not undertake actions concerning the proposed public project that would have a significant adverse effect or limit the choice of alternatives or mitigation measures, before completion of CEQA compliance." "In determining the significance of a project's greenhouse gas emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project's emissions to the effects of climate change. A project's incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. The agency's analysis should consider a timeframe that is appropriate for the project. The agency's analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes." [emphasis added]
Public Resources Code sections 21155.2 and 21159.28,
"environmental documents for certain residential and mixed use projects, and transit priority projects, as defined in section 21155, that are consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in an applicable sustainable communities strategy or alternative planning strategy need not analyze global warming impacts resulting from cars and light duty trucks. A lead agency should consider whether such projects may result in greenhouse gas emissions resulting from other sources, however, consistent with these Guidelines." State Air Resources Board pursuant to Division 25.5
(commencing with Section 38500) of the Health and Safety Code. "To maximize public health, environmental, and employment benefits, the lead agency shall require measures that will reduce the emissions of greenhouse gas[s]es in the project area and in the neighboring communities of the baseball park. Not less than 50 percent of the greenhouse gas emissions reductions necessary to achieve the requirements of this clause, excluding the greenhouse gas emissions from residential uses of the project, shall be from local, direct greenhouse gas emissions reduction measures that give consideration to criteria air pollutant and toxic air contaminant emissions reductions, including, but not limited to, any of the following:
(I) Project design features or onsite reduction measures, or both design features and onsite reduction measures.
(II) Off-site reduction measures in the neighboring communities." Senate Bill No. 32 = CHAPTER 249. An act to add Section 38566 to the Health and Safety Code, relating to greenhouse gas[s]es:
SEC. 2. Section 38566 is added to the Health and Safety Code, to read:
38566. "In adopting rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emissions reductions authorized by this division, the state board shall ensure that statewide greenhouse gas emissions are reduced to at least 40 percent below the statewide greenhouse gas emissions limit no later than December 31, 2030." Synthetic turf off gasses methane and ethylene in ever increasing amounts. Synthetic turf fields create massive toxic heat islands:
Methane traps 90% more heat than carbon dioxide.
Methane is 21 times more potent than carbon dioxide.
Land based plastics produce 2 times more methane and 76 times more ethylene than plastics in waterways and oceans.
GHG emissions of 527 tons of C02e per ten year use period per 7881m2 plastic field. hleat islands extend beyond the footprint of the field, impacting the surrounding community; are visible from satellites in space.
The Lawrence Berkeley National Laboratory, in research released in Apr 2024, found that the plastic industry releases about four times as many planet-warming chemicals as the airline industry - exclusive of agricultural and food packaging plastics. -IE"^^r
s-1
I !:;5Jt 8s
^t%
''^^..a m.'?i.
K ss
t1 m's
K m;i
^•^^.^t'
"K
%tl§x »%•K- RSKms"M
I mt t;
ss;<*~*^
-J m!fe: ».
•I
mmKJy
^<fe
^m
I* t6© m•E3Pf
s^ *1a
^^^^
•».
i
<t •^t» ^«—»>
^("t ) is^I.-
^IPIr'-»>-.t ;s
.^f
a
f»
'<6
I m
181
•(
m^".-»
m
^-m^ •^m^
a
Synthetic turf readily becomes much hotter than nearby asphalt, reaching temperatures of 160°F to 180°F (regardless of infill type) and have even reached over 200°F. Excavation of topsail and compaction of the underlying earth, covering it with layers of plastic, has negative conseQuences for all living organisms and biodiversity. Synthetic turf does not allow natural water filtration, cooling or carbon sequestration.
Pasadena Municipal Code:
Chapter 8.70 - STORMWATER MANAGEMENT AND DISCHARGE CONTROL
8.70.020 - Purpose and intent ((Ord. 6601 § 2 (part), 1994) The purpose of this chapter is to ensure the future health, safety, and general welfare of the residents of the city of Pasadena who recreate in and consume from the waters of the United States, and to protect marine habitats and ecosystems existing therein by:
Regulating non-stormwater discharges to the municipal stormwater system; Providing for the control of spillage, dumping or disposal of materials into the municipal storm-water system;
Reducing pollutants in stormwater and urban runoffto the maximum extent practicable; The intent of this chapter is to protect and enhance water quality of our watercourses, water bodies, and wetlands in a manner pursuant to and consistent with the Federal Clean Water Act, and pursuant to National Pollutant Discharge Elimination System Permit No.
CA0061654, as amended, and any successor legislation and permits,
8.70.030 - Definitions
"Illicit discharge" means any discharge into the municipal stormwater system that is not composed entirely of stormwater except discharges pursuant to a permit, and except discharges otherwise exempted at Section 8.70.060 of this chapter."
"The NPDES permit" means Permit No. CA0061654, and all amendments thereto on file in the office of the city clerk as Agreement No. 15,117."
"Permit" means a National Pollutant Discharge Elimination System permit issued by the California Regional Water Quality Control Board ("CRWQCB"), Los Angeles Region, pursuant to Division 7 of the California Water Code to control discharges from point sources to waters of the United States. "8.70.090 - Reduction of pollutants in stormwater - Cleaning of Parking Lots and Impervious Surfaces.
"Any person owning or operating a paved parking lot, gas station pavement, paved private street or road, or similar impervious surfaces, shall clean those structures frequently and thoroughly to prevent the discharge of pollutants to the municipal stormwater system to the maximum extent practicable. Sweepings or cleaning residue from parking lots and impervious surfaces shall not be swept into or otherwise made or allowed to go into any gutter or roadway,"
Impervious surface:
Synthetic turf is classified as impervious by both the US EPA and the State of California. U.S.
EPA has defined impervious surfaces:
"...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability." It has further defined impervious surfaces as...[a]ny surface that prevents or significantly impedes the infiltration of water into the underlying soil. This can include but is not limited to: roads, driveways, parking areas and other areas created using non porous material; buildings, rooftops, structures, artificial turf and compacted gravel or soil."
Compaction, in addition to the impervious plastic surface, result in increased runoff. Despite synthetic turf industry claims, laboratory testing is not the same as reality. Synthetic turf is unable to handle the amount of rain that comes with an atmospheric river or bomb cyclone.
Augmented by pollutants that accumulate on impervious surfaces (i.e. exhaust; aviation fuels), one inch of rainfall results in 27.000 gallons of toxic runoff per acre. A regulation sized soccer field is 80k square feet (1.84 acres). For areas where snow accumulates on synthetic surfaces, the situation is even more dire as one inch of snow can equal up to 13 inches of rain, significantly increasing the toxic runoff and impacting surface and groundwater, and ultimately drinking water.
|P,A./ADJENA '•I
TURNAROUND,'1
DON'T DROWN
>VtWW-~
;.'.
—r;.'
^...
ii:':
.,...,.^..f^
l.<!
^
E®1
^•«<%<B
.tel?!5W>
Do not drive over standing,
running water!
:.M
.«i»iiied»ldyln
higher ground!
Montr
(fi
:ei-Sw
9 s
C.t>>
tl
<>
M»i.«ffa»—-{">s"'^._..nsian
^""") . / v"1^
;®....,..^*B*
••j^Lf^n i'aA \ \ ^ liwa-
iu'"M I ..\ /^Jsm)/
/•
9"
W'rj
:d,-;ia;-ii>w;!i)(y
—~\,
'.i^rf^n^-9-
-ffi
UM.-^R |
im\ ~11'1"^"" ^a
Potential for erosion:
"As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10-20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, ru no ff is five times that of a forested watershed. Excessive stormwater runoff also increases the potential for flooding." US EPA Impervious Surface Fact Sheet
Scripps Institute of Oceanography, University of California San Diego reported 46 total atmospheric rivers along the U.S. West Coast, causing disastrous flooding and loss of property and life during the 2022 to 2023 rainy season. With what has now been categorized as a Super El Nino year currently, increasing frequency and severity of atmospheric events overall, consideration of synthetic turf is antithetical to environmental responsibility and an even poorer choice for a product that must be replaced every 8 to 10 years on average. ^^^'
>»—»»
Vf
m^
mt
<-^<
".'-
$s"yf. .»a
^s r<f:
s^•"SsS=^
''•*TV
'.'<.'
uafwsssSM,
A;
-a^
^
^
^•t^
Per- and polvfluoroalkvl substances fPFASl:
The Clean Water Act established the National Pollution Discharge Elimination System (NPDES) in 1972. The US EPA works in conjunction with the State Water Resources Control Board (SWRCB), an authorized state permitting authority of the NPDES. Among other pollutants and chemicals of concern, the NPDES program restricts the discharge of PFAS at their sources.
PFAS were first discovered in synthetic turf in 2019 and have been found in every sample and component tested since, including plastic grass blades, backing, shock pads and the two plant based infills tested.
Obtained from public records, PFAS found to date in synthetic turf components and plant based infill include:
D2-N-EtFOSAA
D3-EtFOSA
D9-EtFOSE
6:2 FTS
6:2 FTSA
7:3 FTCA
8:2 FTOH
1202-4:2 FTS
1302-6:2 FTS
1302-8:2 FTS
GenX
D3-MeFOSA
D3-N-MeFOSAA
D7-MeFOSE
MTP
PFBA
PFBS
PFDA
PFHpA
PFHxA
PFHxS
PFNA
PFOA
PFOS
PFPeA
PFPrA
PFTrDA
PMPA
PPF Acid
PTFE
PVDF
R-EVE
Major research on PFAS in synthetic turf by renowned researchers Dr. Graham Peaslee and Dr.
Heather Whitehead is slated to be published in summer of 2024.
Claims by industry to be able to manufacture synthetic turf without PFAS remains completely unsubstantiated and undemonstrated at any level. In the absence of any third-party, independent verification there is no basis for relying on industry claims, particularly given the universal presence of PFAS in all tests to date.
All manufacturers should be able to provide independent third party testing using the most up to date methods or otherwise be able to provide independent third-party testing showing less than one PPM (Part Per Million) ofTOF ^Total Organic Fluorine). Commercial laboratories can test for 90 of the over 14,000 PFAS chemicals at the two PPT (Parts Per Trillion) level. It should be noted that absence of proof is nof proof of absence when only a small percentage ofPFAS can be tested for.
The industry and scientists for hire have been known to manipulate PFAS testing to support misleading and unsupported conclusions. Such deceptive techniques include using methods specific for testing water rather than solids, setting detection limits too high, testing for a narrow range of PFAS amongst the over 14,000 PFAS chemicals, and not testing for Total Organic Fluorine (TOF).
Independent third-party testing for PFAS and TOF using testing methods developed for solids is necessary. Signed affidavits from manufacturers and associated industries have also been proven false, are reportable, and are not acceptable in lieu of independent third-party testing.
On 5 April, the California Office of Health Hazard Assessment (OEHHA) issued a press release regarding Protective Health Goals (PHGs) for two PFAS chemicals, PFOA and PFOS, which will be used by SWRCB to develop Maximum Contaminant Levels (MCLs) for drinking water across the state.
On 10 April 2024, the US EPA issued Maximum Contaminant Level Goals (MCLG) and Maximum Contaminant Levels (MCLs) for both PFOA and PFOS in drinking water:
The US EPA set MCLGs for both PFOA and PFOS at zero.
• MCLs were set at 4.0 ppt for PFOA and PFOS, individually.
MCLGs and MCLs were established for four additional PFAS chemicals: PFNA, PFHxS, PFBS and "GenX" chemicals.
MCLGs and MCLs were established at 10 ppt. MCLs set a limit of 10 ppt for any mixture of two or more of: PFNA, PFHxS, PFBS, and "GenX" chemicals.
All of the named PFAS chemicals have been found in synthetic turf.
Multiple studies have confirmed PFAS, heavy metals, polycyclic aromatic hydrocarbons (PAHs), phthalates and Volatile Organic Compounds (VOCs) leach from and/or aerosolize from plastics.
There is mounting evidence of harm to humans, wild and aquatic life and the environment overall from "forever" PFAS chemicals that bioaccumulate in our food chain and our bodies.
Children are exposed to these toxic and carcinogenic synthetic products in utero, in daycare and preschools, from elementary through high school, in parks- often for hours per day, week on week, year on year. Their exposures can continue through college and beyond. Because of younger children's hand-to-mouth developmental tendencies (ingestion), smaller stature and developmental windows, they are more likely to be exposed to PFAS and other toxic chemicals that leach into air, water and soil from synthetic turf and other plastic products.
PFAS can cause multiple reproductive disorders (including a 40% decrease in female fertility; a decrease of 62.3% total sperm count in males); Crohn's disease; breast, testicular, kidney, prostate and liver cancers. They cross the blood-brain barrier and are related to Autism Spectrum Disorder, Attention Deficit Hyperactivity Disorder, increased deaths from Parkinson's and Alzheimer's diseases; immunological effects; increased serum cholesterol; effects on infant birth weights; impaired glucose metabolism, insulin resistance, dyslipidemia and adiposity in children and adolescents; thyroid hormone disruption (including neonatal) and thyroid cancer.
Hazardous Waste:
Under CEQA, "Hazardous waste is any hazardous material that is discarded, abandoned, or slated to be recycled. Hazardous materials and waste can result in public health hazards if improperly handled, released into the soil or groundwater, or through airborne releases in vapors, fumes, or dust."
PFAS and other toxic and carcinogenic chemicals from synthetic turf are known to leach into au:, water and soil. As the plastic blades, backing and shock pad break down due to age, friction, UV radiation and other environmental exposures, dust is created and released into the environment, posing significant human and environmental risk.
Microplastic blade loss estimates vary widely, from 139 pounds/year (2023) to 551-661 pounds/year. The International Association for Sports and Leisure Facilities states (27 Aug 2019):
"mechanical wear from high tread loads - as arising during football or rugby - causes tiny particles or blades of artificial grass to break off. This amounts to 250 to 300 kg per year for modern sports pitches. "
Even with the best BMPs (Best Management Practices), only a small percentage of the microplastics and virtually none of the PFAS and other toxic chemicals from plastic turf can be captured.
In humans, micro- and nano-plastics have been found in:
Heart • Newborn and adult feces
Liver and spleen • Breastmilk
Lungs • Brain
Blood • Testes and semen
Placenta (maternal and fetal sides)
Microplastic synthetic turf blades have been found in Lake Tahoe and the ocean. In 2021, researchers found that synthetic turf fields in Toronto contribute the 2nd highest amount of microplastics to the environment with only litter contributing a higher amount. This makes synthetic turf clearly a major point source of PFAS and microplastic pollution that cannot go unaddressed.
^-••%^^:-'-^*•-*
^-^^^'^
w^.--..^y1'"" -.-.
i
teri
•'-•h..'/
m
M
.r
•SE^ m^ ^
^ sy
•«
•s-•?? ••.
i;J
s.
Study identifies remains of artificial turf as
important source of pollution in aquatic
environment
\'
•5 ^v/
>-\ ^\
^»(^
Srrm
lh[i in lorn .iti un obfe:nei1 rn lh(; 'eife^'dl hiis befii ci.wipileti iii tiia web!i!!s ihat sfcwcs flK a wwle gu'de lu i... m.aBi^
m^
iti:
»
H
8 i;
;1
3SV;
MsiS 1;
^mm.m
%M s-
aa;
•^?^'i@1?^^
£v%
•llK
1^
K
On 13 December, the CA Coastal Commission conditioned a permit for the Cesar Uyesaka Baseball stadium, requiring NATURAL GRASS, citing microplastic pollution.
Cumulative impacts under CEQA
Synthetic turf will off-gass large amounts of greenhouse gasses Synthetic turf contributes to climate change, which has negative impacts on wild and aquatic life
Synthetic turf will "provide substantial additional sources of polluted runoff' Synthetic turf and plastics leach PFAS and other toxic chemicals known to bioaccumulate in wild and aquatic and plant life; negatively impacts the food chain Synthetic turf will "cause substantial adverse effects on human beings, either directly or indirectly" via:
Toxic and carcinogenic chemicals known to be bioaccessible and bioaccumulative Heat impacts: Heat islands/Heat illness/heat stroke/death Increased utility costs for cooling; greater impact on social justice communities where air conditioning is less likely
Mental health impacts due to loss of green space
Increased injuries compared to natural grass
Thermal and friction burns
Concussions
Not recyclable - per 80k sq ft playing field: 40,000 pounds of plastic waste to be landfilled or inappropriately discarded every 8 to 10 years on average; 400,000+ pounds of infill poured between plastic blades
Hazardous waste/Microplastic pollution - synthetic turf blades contribute 15% of macro- and mesoplastic pollution to waterways and the ocean.
Significant point sources of pollution
Degrade into microplastics, taking approximately 1000 years to fully decompose.
Increased off gassing of GHGs with greater degradation (increases surface area) Continues to leach chemicals; adsorbs bacteria and other chemicals **
**
•*•*
**
**
**
**
**
**
**
**
2. SB676 - CHAPTER 498
An act to amend Section 53087.7 of the Government Code, relating to local government The wording in 2. is misleading decision makers by co-opting language from the 2016 law that is no longer in effect due to chapterting of SB676 into law.
SB 676- specifies "drought-tolerant landscaping does not include the installation of synthetic grass or artificial turf." An analysis of SB676 notes "...emerging research reveals that artificial turf incurs significant environmental problems including microplastic pollution, chemical run-offand lack of recyclability."
Thirty one environmental and health organizations signed on in support ofSB676. There was no opposition to the bill.
In a press release issued 4 March 2024, the CEO of the Center for Environmental Health (CEhl) in Oakland, CA stated:
"No one should be inadvertently exposed to toxic chemicals. Our lawns are places in our homes where we should be able to play and relax, safely. They should not be spaces where we worry about exposing ourselves to harm. Touching artificial turf lawns can expose us to PFAS chemicals when transferred from the turf to our hands and then our mouth."
CEhH sent a Notice of Violation under the California Safe Drinking Water and Toxic Enforcement Act (Proposition 65) for Perfluorooctane Sulfonate (PFOS) in synthetic turf sold by Lowes and Home Depot since at least March 2021. Both big box stores had made previous commitments to selling PFAS free carpeting and failed to notify customers of the carcinogenic PFAS chemicals in the products they sold. Synthetic turf is plastic grass carpeting, made by the same manufacturers and often in the same locations as household and commercial carpeting.
CA Health & Safety Code Section 25249.6
"Required Warning Before Exposure To Chemicals Known to Cause Cancer Or Reproductive Toxicity. No person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning to such individual, except as provided in Section 25249.10."
No one should be exposed to the toxic runoff, the heat or off gassing of toxic methane and ethylene, nor the microplastic pollution from their neighbor's yard.
CA Department of Toxic Substances Control (DTSCt:
"Synthetic turf, the backing and fiber layers are made of similar materials as carpets and rugs, such as polyvinyl chloride, polypropylene, nylon, and polyurethane...lt is estimated that by the end of 2020, 750 fields will be replaced each year, with the average field containing approximately 40,000 pounds of plastic carpet and 400,000 pounds of infill, accounting for over 300 million pounds of waste annually (STC 2017)."
"The use of artificial turf at outdoor facilities is of concern since they are frequently used by sensitive subpopulations, including young children. While air circulation is generally better in an outdoor application, there is also an increased potential for exposure to Candidate Chemicals in turf due to faster material degradation by outdoor elements, such as ultraviolet light, and high-fhction athletic use; in addition to increasing the release of chemicals from artificial turf during use, these factors also affect the product's life and make it necessary to replace it every eight to 10 years (STC 2017)."
httDS://dtsc.ca.aov/WD-content/UDloads/sites/31/2021/04/Final-2021-2023-Prioritv-Product-Work- Plan.pdf
DTSC has already brought PFAS in residential and commercial carpets under regulation. They will be holding a public meeting on PFAS and other chemical categories of concern in synthetic turf in the near future.
Viable Alternative:
Grass fields actively sequester carbon dioxide and provide a cooling function that is especially dramatic when compared to the heat generated by synthetic turf. Grass naturally filters toxins, performs important eco-services for the soil beneath, and provides widely dispersed rainwater infiltration allowing absorption and recharging of the water table. Additionally:
• Research suggests that grasses can accumulate and deposit carbon into the soil by approximately one-half ton of carbon per acre per year for 30 to 40 years. • Net carbon sequestration rates in urban lawns have been estimated at between 200 and 1,800 Ibs of carbon per acre per year.
• Organic management and zero emission maintenance equipment mitigate emissions, reduce costs overtime, and increase carbon sequestration. • Electric mowers for playing fields and chalk markers are available. • Drought and desert tolerant varieties of natural grass appropriate for lawns, parks and high use playing fields are available.
• With soil sampling and soil food biome analysis, appropriate drought tolerant seed or sod selection, professionally installed and maintained natural grass can last without replacement for 30 years (Jerad Minnick), High-use natural grass sports surface specialist; Management, Maryland SoccerPlex; Owner, Natural Grass Advisory Group™.
A turfgrass manager (not gardeners or landscapers) can generally manage 5 natural grass playing fields. Hiring or training turfgrass managers would be a cost effective investment with the savings realized from drought tolerant natural grass rather than the exorbitant expense for plastic fields that last from 8-10 years on average (some have failed as early as 1 to 4 years). It should be noted that synthetic turf may not be replaceable with legislation and/or upcoming regulation.
Plastic grass carpet is merely a way to attempt to sweep tack of maintenance of natural grass fields under the rug. It is not "set it and forget it." Failure to maintain synthetic turf, whether in residential or other applications, including costly cleaning with toxic chemicals, testing for hardness, replacing lost infill and timely repairs can void a warranty almost as quickly as it is installed. Installation, maintenance, removal, disposal and replacement (if possible in the future) should not be a taxpayer burden - particularly when it poses clear risks to humans, wild and aquatic life and the environment.
WHY IS TURF MAINTENANCE IMPORTANT? ^
Synthetic turf surfaces go through heavy usage and high traffic. Because of this, even the smallest installation collects debris over time. From bobby pins and magnetic objects to broken pieces of athletic equipment, dirt, and unwanted fluids, synthetic turf surfaces are constantly contaminated. Because of this, surfaces require optimal sports field cleanings. 2S3SS ft'?lhWS T-Wfa'WnPflfRumM!tWnWW»WW*5i^]EW iii:!i)!EM)11^ jConstant sports field maintenance and care is crucial to maximizing the life of a synthetic ^•^ ^^^^'.,:^.^^uL'^;^',;^^^y^^t^ffit!»SdEi^yffi^i[»^
every Matrix Turf surface it installs. Hellas provides clients with all the tools and information necessary to maintain the took, feel, and playability of artificial turf surfaces.
Hellas has developed an array of both machinery and services that address every maintenance need for fields, including de-compactors, repair tools, and disinfectant sprays. With Hellas' service and maintenance, taking care of a turf sports surface is a simple and almost automatic experience that brings life to the surface and safety to sports athletes.
California communities taking action:
Millbrae: banned synthetic turf effective 1 January 2024 San Marino: instituted an interim ordinance prior to signing of SB676. Effective through 12 September 2024.
Sunnyvale: committed to undertaking a study relating to the use of synthetic turf in January 2024.
Santa Clara County: staff was directed to bring a draft ordinance to the Board of Supervisors in June 2024, pending receipt and inclusion of a second report from the Santa Clara County Medical Association,
Additional commissions and committees are beginning the process of considering this important issue impacting human and environmental health.
We urge the city of Pasadena to support an ordinance that would ban use of toxic synthetic turf on residential and all city owned and leased land. Protection of human and environmental health is a fiduciary, ethical and moral responsibility.
Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
httDs://www.safehealthvDlavinafields.ora
SHPFI is an all-volunteer nonprofit 501-c-3
t1rSAFE HEAITHY,
PLAYING FIELDS
~^Ss^
i3 BEYOND PLASTICS
AFFILIATE