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From: Zoe
To: LUCY F STONE; [email protected]
Cc: Christian Tago; Halima Barreto; councilmtgitems; Lana Negrete; Douglas Sloan; Josh Kurpies; [email protected]; Ramon Batista; David Gardinier; Darrick Jacob; Caroline Torosis; Jesse Zwick; Ellis Raskin; Natalya Zernitskaya; Barry Snell; Dan Hall; Clerk Mailbox; Susan Cline; Elaine Polachek Subject: Re: 25STRO01187 Notice of Ex-Parte Application & Copy of the Returned TRO Date: Thursday, March 20, 2025 11:33:03 AM
EXTERNAL
Ms. Stone,
I beg your pardon, I do not recall including you in my email. The email is not for you, the email is for Sean Besser and the Board of the Ocean Park Neighborhood Association.
As a resident of the Ocean Park Neighborhood, I am allowed to send emails to the public address of the organization that receives public funds from the City of Santa Monica. I am including the Chief of the Santa Monica Police along with its Deputy Chief, The Santa Monica City Manager and the Santa Monica City Attorney in this email so they can help you understand how transparency and ethical use of funds by neighborhood associations work.
I do remember you were one of the attendees at the May 5, 2024 Compassionate Santa Monica event hosted at Gooseegg Park last Spring. Long time since I saw you for the last time, I do not understand the hostility of your email, I have been very welcoming, hospitable, and nice to you. Perhaps you were sent to the event as an informant to see the way we managed to bring to the attention of the Santa Monica Social Justice and DEI Department our findings through the City Wide Equity Plan. It seems ironic to me that you voluntarily attended an event that supports the work of the Santa Monica Citywide Equity and a year later chose to write to me with hostility.
You should understand that in today's political climate, a Caucasian woman (you) speaking to a woman of color (me), should consider elements of cultural competence.
Training and resources are available online to express yourself with more dignity and respect. As a Board member from OPA you represent a Neighborhood, not just yourself. be kind, it does not cost you anything.
Last week, the Executive Director of The Charter for Compassion sent me an email in reference to a "group" that contacted her to ask that Santa Monica Chapter be removed from the website of the Charter for Compassion. Please note that Compassionate Santa Monica was born from a September 23, 2013 presentation that brought a unanimous vote authorizing the City Manager to sign the Charter for Compassion. No "organization" can go behind to cancel an official vote of the Santa Monica City Council.
I request that the Santa Monica City Clerk includes this email as part of next week's City Council Meeting.
Have a blessed weekend.
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On Thu, Mar 20, 2025 at 11:01 AM LUCY F STONE <[email protected]> wrote:
PLEASE...
DO NOT send me any more emails.
Thank you.
Lucy Frances Stone
On Thu, Mar 20, 2025, 10:51 AM Zoe <[email protected]> wrote:
Please take notice that on March 21, 2025 at 8:30 AM or soon after that as the matter can be heard, in Department 65 Room 302 of the Metropolitan Courthouse, located at 1945 South Hill Street, Los Angeles, CA 90007, Defendant Zoë Muntaner will and does move the Court by an Ex Parte Application for Notice of Motion and Motion to Dismiss and Terminate the (meritless) Request for Civil Harassment Restraining Orders, to the first available hearing date or in the alternative shortening time for the hearing.
Furthermore I am including a copy of the Civil Harassment Restraining Orders papers served to you by LASD Deputy Sheriff Ramirez at the Courtroom yesterday. The documents were received by you and later returned after more than 230 minutes in your possession;that is not an option after receiving, reading, evaluating and keeping court documents. The LASD have been informed.
Zoё Muntaner
“Do you have the patience to wait till your mud settles and the water is clear?"- Tao Te Ching IMPORTANT WARNING: This email (and any attachments) is only intended for the use of the person or entity to which it is addressed to and may contain privileged and confidential information. You, the recipient, are obligated to maintain it safely, securely, and confidentially. Unauthorized redisclosure or failure to maintain confidentiality may subject you to federal and state penalties. If you are not the intended recipient, please immediately notify me by return email and delete this message from your computer. --
Zoё Muntaner
“Do you have the patience to wait till your mud settles and the water is clear?"- Tao Te Ching IMPORTANT WARNING: This email (and any attachments) is only intended for the use of the person or entity to which it is addressed to and may contain privileged and confidential information. You, the recipient, are obligated to maintain it safely, securely, and confidentially. Unauthorized redisclosure or failure to maintain confidentiality may subject Item 1
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you to federal and state penalties. If you are not the intended recipient, please immediately notify me by return email and delete this message from your computer.
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1 David Yakobson
From: Debra Shepherd <[email protected]>
Sent: Tuesday, March 25, 2025 9:13 AM
To: councilmtgitems
Subject: Item 1
EXTERNAL
Council members:
I am writing to you as a housing voucher holder. I was recently accused of violating housing quality standards by the for profit property owner, where I reside. I have been a voucher holder here in Santa Monica for over 20 years due to disability. I have used my voucher in Santa Monica at two addresses. I have never been written up for any misconduct by the Housing Authority. I have always treated the staff with civility and respect. I was complimented on my professionalism by my former housing specialist several times, and I was asked multiple times to apply to sit on the Housing Authority Board.
This allegation from the property owner was in retaliation for a small claims judgment that my daughter received against them. They tried to weaponize the Housing Authority against me in November of 2024, but the inspection was canceled due my daughter’s medical appointment. Everyone in my family is disabled. My daughter has a chronic illness. She almost died in 2022. My doctor has provided documentation that it is very difficult to obtain and change appointments at UCLA. When a person is a patient there, that needs to be considered.
In February 2025, after the Palisades fires, the property owner circled back with their allegation of violating housing quality standards, in an effort to constructively evict my family from our rent controlled, Section 8 home. They have a history of racism and discrimination against my family.
When I complained to the Housing Authority, I was coldly admonished to go to Legal Aid. I was not explained the specifics of the allegation, nor was I provided with anything with my rights on it. I was also not told where I could access my rights.
The special inspection took place on February 11, 2025. The housing inspector was rude to me, but provided the property owner with preferential treatment. Even though the inspector wrote the property owner up for multiple violations, I was only told to do one thing, which I did immediately. It did not meet the standard of an eviction or termination of my voucher.
For the follow up, the letter that I received had a harsh tone. It threatened to terminate my housing if I missed the appointment. I have never missed an appointment, been late with paperwork, or refused to do anything that was asked of me. The harsh tone is unnecessary and inappropriate. No housing voucher holder should be threatened with homelessness as standard practice. That is a cruel and inhumane practice. It does not take into consideration the fact that many voucher holders carry the trauma of homelessness. Reliving that trauma might cause someone to end their life. That’s not okay. Please be more considerate of the way that you treat voucher holders. No one deserves to be traumatized over and over again as standard procedures.
Regards,
Debra Shepherd
Santa Monica resident and voucher holder Sent from my iPad Item 1
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2 David Yakobson
From: John Alle <[email protected]>
Sent: Tuesday, March 25, 2025 7:52 AM
To: The Santa Monica Coalition Organizer
Cc: John Alle
Subject: Tuesday
EXTERNAL
There are NO statistics that exist or show "diversion" treatment works. There are not even funds available for research or tracking. The charges against this criminal will be dismissed in 24 months. His record will be expunged.
This doesn't even happen with a DUI conviction. No pill or psychotherapy will change one's character or inherent evil.
Insta
https://www.instagram.com/reel/DHoBQTjC6uW/?utm_source=ig_web_copy_link&igsh=MzRlODBiNWFlZA== YouTube
https://youtu.be/9HQHfEcgUtA
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1 David Yakobson
From: Wendy Dembo <[email protected]>
Sent: Monday, March 17, 2025 7:18 PM
To: Planning Commission Comments; councilmtgitems
Subject: Planning Commission item for 3/19/25 - Item 11B. - DO NOT increase heights of fences, walls and hedges in front setbacks of R2, R3 and R4
EXTERNAL
Dear Planning Commission and City Council,
I oppose increasing the maximum allowed heights for fences, walls, and hedges, and rules including those located on top of retaining walls. Why? I live on 21st Street, which is zoned R2. There aren't enough lights in my immediate neighborhood. Adding tall hedges and walls would make it even scarier.
* SMMC Section 9.21.050(A)(1) which allows fences, walls and hedges up to 42 inches in the front setback within all zoning districts including R1, R2, R3, and R4 already have an option to apply for a discretionary height modification should additional height be requested under SMMC Section 9.43.050(B).
The Santa Monica Police Department has explained to residents that while a person may feel safe when living behind high walls, that safety is an illusion because of obscured sight lines, diminished ambient, street, and security lighting, and reduced access by law enforcement and less interaction between
neighbors contribute to making a neighborhood less
safe, not more.
* If the increased height is implemented, given the increasing density of the city as noted in the staff report, there will be no review to determine if increasing heights will yield visual obstructions to pedestrians, drivers, and cyclists. Section
91.21.180 Hazardous Visual Obstructions code will be more prevalent but not looked at and addressed less than it would be in a discretionary height modification request.
* The city has a limited enforcement ability and the 50% transparency for walls and fences above 42 inches in height will be unenforceable and untenable. Please keep the code as it is.
* I believe the higher hedges will make buildings less safe from fires and as they get older and higher even more of a fire hazard, especially if the five feet height and the additional height on retaining walls are not enforced
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2 * The Wilmont neighborhood is the densest in the city with only R2 and R3 zoning in our neighborhood. The staff report states, “Through the City’s public outreach process, members of the community expressed support for increased maximum heights for fences, walls, and hedges in the front setbacks of properties located within the R2, R,3, and R4 zoning districts”. Even though we solely have R2 and R3 zones and the most populous and dense neighborhood, Wilmont Board and its residents were not engaged in an outreach effort missing over 50% of the city’s residents who reside in R2 and R3 multi-unit dwelling zones. Whose opinions were sought in this outreach?
* City codes are made to better support all residents. If a resident has an issue they have a solution. They can apply for a discretionary height modification should additional heights be requested under SMMC Section 9.43.050(B). * I support keeping the process and code the same as it is for R1.
Thank you for your time and consideration of our issues and concerns.
Wendy Dembo
Santa Monica Resident, Voter, and Wilmont Board Member
Board of Wilshire Montana Neighborhood Coalition (Wilmont) Item 1
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1 David Yakobson
From: D Woelke <[email protected]>
Sent: Monday, March 17, 2025 5:01 PM
To: Recreation and Arts Department; Environment Mailbox; Rachel Kwok; councilmtgitems Cc: Clerk Mailbox; Noe Mendoza
Subject: Re: For the public record: Memorial Park Redevelopment and Expansion Project Attachments: Santa Monica playground.pdf; Santa Monica 12 Mar 2025.pdf Follow Up Flag: Follow up
Flag Status: Flagged
EXTERNAL
Good evening:
Attached please find our comments regarding the proposed playground at Memorial Park.
Kindly distribute copies electronically so that those who wish to avail themselves of source citations may do so.
It is our hope that Santa Monica chooses natural solutions, and moves away from products that induce climate change, negatively impact biodiversity and contribute to the tsunami of toxic and carcinogenic plastic waste.
We would be happy to answer any questions or discuss any of the points raised in the attached document or any other aspect related to synthetic turf or playground surfacing, as these comments are directed more towards the environmental impacts.
Best regards,
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
On Mar 11, 2025, at 11:01 PM, D Woelke <[email protected]> wrote:
Good morning:
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2 Attached please find our comments regarding the proposed synthetic turf playing fields for the above project. We will submit comments regarding the proposed playground separately.
Kindly distribute copies electronically so that those who wish to avail themselves of source citations may do so.
It is our hope that Santa Monica redirects, chooses natural solutions, and moves away from products that induce climate change, negatively impact biodiversity and contribute to the tsunami of toxic and carcinogenic plastic waste.
We would be happy to answer any questions or discuss any of the points raised in the attached document or any other aspect related to synthetic turf, as these comments are directed more towards the environmental impacts.
Best regards,
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
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Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
17 March 2025
Memorial Park Redevelopment and Expansion Project
Playground
Santa Monica City Council, Environmental Planning and Parks and Recreation Departments and Commission:
These comments are submitted by Safe Healthy Playing Fields, Inc. (SHPFI). As an all-volunteer 501-c-3 non-profit, we are committed to educating communities, policymakers 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.
We are writing to urge you to condition all projects within Santa Monica to not use used tire crumb or mulches (bound or unbound) for playgrounds, pools, waterparks, landscaping and rubberized asphalt driveway and road additives- all places where people recreate. Toxic chemicals from these products can leach into the air, water and soil, and can be absorbed via skin, inhaled and ingested, making protection of both human and environmental health necessary.
Title 14. Natural Resources. Division 6. California Natural Resources Agency Chapter 3.
Guidelines for the Implementation of the California Environmental Quality Act, Article 1. General§ 15004. Time of Preparation
“…public agencies shall not undertake actions concerning the proposed public project that would (2) have a significant adverse effect or limit the choice of alternatives or mitigation measures, before completion of CEQA compliance.”
“The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes.”
CA REGULATORY SCHEMES and LAW:
CA DTSC - Microplastics, addition to Priority Chemicals List CA DTSC - 6PPD in Motor Vehicle Tires
CA DTSC - Zinc in Motor Vehicle Tires
CA DTSC - Chemicals of Concern in Motor Vehicle Tires.
CA DTSC - Phthalates,Styrene, and Formaldehyde in Children’s Products CA Statewide Microplastics Strategy - Senate Bill No. 1263, Chapter 609, 2018 Item 1
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Plastics and Playground Equipment:
By using plastic playground surfacing and equipment in the proposed all-inclusive playground in Memorial Park, Santa Monica will increase risk and harm from toxic and carcinogenic chemicals in these products and microplastics released from them, to vulnerable populations,1,2,3 exclude deaf and hearing impaired individuals, and cause extensive environmental harm.
Plastic playground equipment poses significant risk from chemical exposure via dermal contact, inhalation and ingestion. Young children are particularly vulnerable to chemical exposure due to developmental windows.
Plastic playground equipment, particularly slides, create an equity barrier for hearing impaired children and adults with cochlear implants (CI).4 Static builds up and can completely wipe out internal software in implants, requiring an expensive visit to a CI audiologist for re-installation.
The alternative would be to remove implants during play on these surfaces, imposing risk of injury when a child cannot hear caregivers. It also leaves a child to play in silence, negatively impacting necessary social interaction skills required for development.
It is possible to construct playgrounds without using plastic surfacing (i.e. used tire crumb, ethylene propylene deine monomer, polyvinyl chloride) and still meet Americans with Disabilities Act (ADA) requirements. ADA addresses accessibility, not surfacing.5 “The accessibility standards are minimum standards and do not require the entire play surface area to be accessible. The only required accessible surface area includes the accessible route from the entry of the play area, at least one connection to each accessible play component (points of entry and egress) and any clear space requirements adjacent to accessible play components.”6
Accessibility to the playground can be achieved via a concrete walkway, wooden, aluminum or similar ramp, or use of a “mobi-mat” that extends from the boardwalk towards the water. These 6 US Access Board (2014). “Surfacing the Accessible Playground: 7 Things Every Playground Owner Should Know About the Accessibility of Their Playground Surfaces.” https://www.access-board.gov/ada/guides/chapter-10-play-surfaces/# 5 Pollard, L, Massey, R (Dec 2023). “Playground Surfacing: Choosing Safer Materials for Children's Health and the Environment.” Toxics Use Reduction Institute, Univ. Massachusetts, Lowell. https://www.uml.edu/docs/Playground_surfacing_report_Dec2023_tcm18-377890.pdf 4 Miracle Recreation. Playgrounds for Hearing Impaired Children https://www.miracle-recreation.com/blog/hearing-impaired-playgrounds/ 3 Flaws, J, Damdimopoulou, P, Patisaul. HB et al (10 Dec 2020). “Plastics, EDCs & Health. A Guide for Public Interest, Organizations and Policy Makers on Endocrine Disrupting Chemicals & Plastics.” The Endocrine Society with International Pollutants Elimination Network (IPEN). https://ipen.org/sites/default/files/documents/edc_guide_2020_v1_6ew-en.pdf 2 Geneva Environmental Network. Plastics and Human Health | Plastics and the Environment Series/ https://www.genevaenvironmentnetwork.org/resources/updates/plastics-and-health/ 1 Center for Diseases Control and Prevention. Child Development: Developmental Disability Basics. https://www.cdc.gov/child-development/about/developmental-disability-basics.html Item 1
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mats are generally made of nylon, another plastic. Positioning of playground equipment so that there is a shorter distance to the lowest access point of a structure can also help reduce costs.
Per- and Polyfluoroalkyl Substances (PFAS);
“It’s not an acute toxin. It’s chronic, so it affects you by long-term exposure…There are no safe kinds. I’ve yet to see one that doesn’t cause some sort of cancer or immunosuppression.” Dr. Graham Peaslee
There are over 16,000 known chemicals found in plastics. Of the known chemicals, 4,200 are considered “highly hazardous” to human and environmental health. Of these 4,200 chemicals, only 980 have been regulated by any global agency. Per- and polyfluoroalkyl substances (PFAS) are amongst the 15 categories of chemicals of concern in plastics. 7 Chemicals in plastics, including polybrominated diphenylethers (PBDE), neurotoxic phthalates, bisphenols and PFAS, add disease burden and health care costs in the United States. For 2018, the attributable cost of plastics to disease and health care related costs was $249 billion; for PFAS alone, it was $22.4 billion.8 The societal cost globally is estimated at $16 trillion9 annually for PFAS clean ups and health care for impacted individuals.
The need to stop further PFAS exposure cannot be overstated.10 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. Because they are bioaccumulative, PFAS exposure can impact multiple generations. Babies are being born pre-polluted with PFAS.
(*source citations for all available upon request)
10 CA Dept. Toxic Substances Control. “PFAS Fact Sheet.” CA EPA. https://dtsc.ca.gov/wp-content/uploads/sites/31/2023/09/PFAS-Factsheet.pdf 9 Staff writer (23 May 2023). “ChemSec identifies the top 12 PFAS producers in the world and reveals shocking societal costs. PRESS RELEASE: The global societal costs of PFAS chemicals amount to €16 trillion per year.” ChemSec, Norway.
https://chemsec.org/chemsec-identifies-the-top-12-pfas-producers-in-the-world-and-reveals-shocki 8 Trasande, L, Krithivasan, R, Park, K et al (Feb 2024). “Chemicals Used in Plastic Materials: An Estimate of the Attributable Disease Burden and Costs in the United States.” Journal of the Endocrine Society: (8), 2.
https://doi.org/10.1210/jendso/bvad163
7 Wagner, M, Monclús, L, Arp, HPH et al (Mar 2024). “State of the science on plastic chemicals:
Identifying and addressing chemicals and polymers of concern.” PlastChem, Norway. https://plastchem-project.org
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As the body heats, it is susceptible to absorbing more chemicals such as PFAS.11
11 Ragnarsdóttir, O, Abou-Elwafa Abdallah, M, Harrad, S (June 2024). “Dermal bioavailability of perfluoroalkyl substances using in vitro 3D human skin equivalent models.” Environment International; 188; 108772.b https://www.sciencedirect.com/science/article/pii/S0160412024003581?via=ihub Item 1
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Surfacing materials:
SHPFI supports the use of natural, non-toxic surfacing for playgrounds:
● Engineered wood fiber (EWF)
● Wood chips/bark
● Pea gravel
● Sand
Chemical binders used for EWF, rubber or wood mulch and cork PIP (pour in place) surfacing contain toxic and carcinogenic chemicals, including, but not limited Chemistry and Analytical Sciences (CAS) registration numbers :
● Polymethylenepolyphenyl polyisocyanate, polypropyleneglycol copolymer; CAS #53862-89-8;
● Diphenylmethane Diisocyanate, isomers and homologues; CAS #9016-87-9; ● 4,4'-Methylenediphenyl diisocynate; CAS #101-68-8.
Additionally, these chemical binders do not “bind” for long. They also break down even more quickly in hot, humid and wet environments.
It should be noted that “natural rubber,”12 whether in mulch, shredded, tile or mat form, is still a petrochemical synthetic plastic and contains many of the chemicals found in tires, minus the debris from road use. Natural rubber, in this context, does not come from the sap of rubber trees. It is equivalent to ethylene propylene diene monomer (EPDM) and thermoplastic vulcanizate (TPV).
The following statement, initially applied to the disastrous effects of rubberized asphalt, is even more relevant for used tire crumb infill and playgrounds:
“What at first seemed like a brilliant way to get rid of mountains of old tires has given new meaning to the old saying about what paves the road to hell.”13
Select Chemicals in Used Tire Crumb Surfacing:
Used tire crumb has been widely used in playground surfacing, known as poured in place (PIP) surfacing. It has come under scrutiny in recent years due to the hundreds of toxic and carcinogenic chemicals it contains, which can leach into air, water and soil and their negative impacts on human and environmental health. Tire crumbs are microplastics.
The California Coastal Commission declined two recent permits for playground surfacing at Newport Beach Elementary School and a planned project for a playground in Mission Bay, San Diego.
13 Andersen, P. Where Rubber Meets the Road, It’s a Mess. 21 Apr 1996. Los Angeles Times. https://www.latimes.com/archives/la-xpm-1996-04-21-mn-60932-story.html 12 LibreTexts Chemistry. Natural and synthetic rubbers. https://chem.libretexts.org/Bookshelves/Organic_Chemistry/Map:_Organic_Chemistry_(Smith)/24:_Synth etic_Polymers/24.05:_Natural_and_Synthetic_Rubbers
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6PPD, 6PPDquinone:
On 15 July 2021, Representative Katie Porter, then chair of the US House of Representatives Natural Resources Committee, Sub-committee on Oversight and Investigations, held a hearing on toxic chemicals from car tires and playing surfaces.14 This was in response to the December 2020 discovery of the antiozonant
N-(1,3-dimethylbutyl)-N-phenyl-p-phenylenediamine (6PPD) in tires. 6PPD converts to 6PPD-quinone (6PPDq) when it interacts with ozone.15 6PPDq has resulted in a 40-90% decline in coho salmon populations- a federally designated endangered species that is also implicated in US treaties with several Native American Tribes.16,17 In addition to coho salmon, 6PPDq has also been found to be acutely toxic to rainbow and brook trout.18 “Even if this harmful chemical was removed from tire production today, we will be dealing with the legacy of its use for the next 15 to 20 years.” Nisqually Tribe biologist, David Troutt.19
“6PPD is more toxic than Mercury, 27 times more toxic than Cyanide, 425 times more toxic than Arsenic and more toxic than DDT...we do know that all those same ingredients in the chemical reaction that kills salmon are in those playground and playing surfaces...What we need is research on the risks from 6PPD quinone and on the possible substitutes. We need to treat this with urgency befitting a danger to our children.” 8
“…tire chemicals are also a concern for the effects of air pollution on human health.
The smallest particles that wear from tires contribute to the particle pollution of air. 19 Troutt, D (15 July 2021). Testimony before US House of Representatives Natural Resources Committee, Oversight and Investigations Subcommittee on 6PPDq impact on coho salmon. https://docs.house.gov/meetings/II/II15/20210715/112886/HHRG-117-II15-Bio-TrouttD-20210715.pdf 18 Brinkmann, M, Montgomery, D, Selinger, S et al (2 Mar 2022). “Acute Toxicity of the Tire Rubber-Derived Chemical 6PPD-quinone to Four Fishes of Commercial, Cultural, and Ecological Importance.” Environmental Science and Technology Letters. 9 (4): 333–338 https://pubs.acs.org/doi/10.1021/acs.estlett.2c00050
17 Middleton Manning, R, Lusardi, R (13 July 2023). “Removing Dams from the Klamath River is a Step Toward Justice for Native Americans.” Climate News, UC Davis. https://www.ucdavis.edu/climate/news/removing-dams-klamath-river-step-toward-justice-native-americans -northern-california
16 NOAA fisheries: Coho salmon,
https://www.fisheries.noaa.gov/species/coho-salmon
15 Tian, Z, Zhao, H, Peter, KT et al (2020). “A ubiquitous tire rubber–derived chemical induces acute mortality in coho salmon.” Science; (371, 6525a.
https://www.science.org/doi/10.1126/science.abd6951
14 Porter, K, Chair (15 Jul 2021). A congressional hearing: “Are Toxic Chemicals fromTires and Playground Surfaces Killing Endangered Salmon?” US House of Representatives Natural Resources Committee, Oversight and Investigations Subcommittee.
2021https://democrats-naturalresources.house.gov/hearings/are-toxic-chemicals-from-tires-and-playgrou nd-surfaces-killing-endangered-salmon
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These particles are inhaled when we breathe, and they release chemicals when they settle on the wet surfaces inside our lungs. We know that humans living closer to busy roads have poorer health outcomes due to air pollution. It is important that we learn whether 6PPD-quinone plays a role in the toxicity documented when human cells are exposed to chemicals released from tires…Studies are needed to determine the relative contributions of 6PPD-quinone from tires during their use on vehicles as well as the various end-of-life uses of tires such as crumb rubber in playgrounds and synthetic turf fields.” 20
Synthetic playing fields and playgrounds have been shown to be contributing factors. 6PPD and 6PPDq are the latest in an extremely lengthy list of chemicals that are harmful to human and environmental health, as they can be ingested, inhaled, absorbed via skin,21,22 and negatively impact animal and human liver cells.23
The San Francisco Estuary Institute 2021 report submitted to the California Ocean Protection Council found that tire wear particles contributed 85% of microplastics in stormwater runoff across 12 test sites in the bay area. Playgrounds, rubber infill for synthetic turf and rubberized asphalt were all found to be contributing sources of tire particles in urban runoff.24 24 Werbowski, LM, Gilbreath, AN, Munno, K et al (2021). “Urban Stormwater Runoff: A Major Pathway for Anthropogenic Particles, Black Rubbery Fragments, and Other Types of Microplastics to Urban Receiving Waters.” ACS ES&T Water; 1 (6), 1420-1428.
https://pubs.acs.org/doi/full/10.1021/acsestwater.1c00017 23 Qi, Y, Qiu, A, Wei, X et al (2024). "Effects of 6PPD-Quinone on Human Liver Cell Lines as Revealed with Cell Viability Assay and Metabolomics Analysis" Toxics 12, no. 6: 389. https://doi.org/10.3390/toxics12060389
22 Chen, X, Le, Y, Wang, W et al (5 May 2025). “p-Phenylenediamines and their derived quinones: A review of their environmental fate, human exposure, and biological toxicity.” Journal of Hazardous Materials; 488, 137373.
https://www.sciencedirect.com/science/article/abs/pii/S0304389425002857 21 Wan, X, Liang, G, Wang, G (1 Nov 2024). “Potential human health risk of the emerging environmental contaminant 6-PPD quinone.” Sci of Total Environment; (949), 175057. https://www.sciencedirect.com/science/article/abs/pii/S0048969724052070 20 McIntyre, J. (15 July 2021). Testimony before US House of Representatives Natural Resources Committee, Oversight and Investigations Subcommittee on 6PPDq impact on coho salmon.
McIntyre, J (15 Jul 2021). Testimony before US House of Rep., Natural Resources sub committee.
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Multiple studies on used tire crumb have confirmed chemicals of concern to both human health and the environment.25,26,27,28,29 Korean researchers have found that children who play on crumb rubber are 10 times more likely to develop cancer than those who play on soil.30 In 2023, research published by UCLA in conjunction with the Moore Institute for Plastic Pollution Research found playgrounds in parks release as much as five times greater microplastics from equipment and surfacing than other areas in parks.31 This makes synthetic turf and rubber 31 Koutnik, VS, Leonard, J, El Rassi, LA et al (1 Jan 2023). “Children's playgrounds contain more microplastics than other areas in urban parks.” Science of The Total Environment; (854)158866. https://doi.org/10.1016/j.scitotenv.2022.158866
30 Tarafdar, A, Oh, MJ, Nguyen-Phuong, Q et al (2020). “Profiling and Potential Cancer Risk Assessment on Children Exposed to PAHs in Playground Dust/Soil: A Comparative Study on Poured Rubber Surfaced and Classical Soil Playgrounds in Seoul.” Environ Geochem Health 42, 1691–1704 https://doi.org/10.1007/s10653-019-00334-2
29 Armada, D, Llompart, M, Celeiro, M et al (15 March 2022). “Global evaluation of the chemical hazard of recycled tire crumb rubber employed on worldwide synthetic turf football pitches.” Science of Total Environment; (812), 152542.
https://doi.org/10.1016/j.scitotenv.2021.152542
28 Duque-Villaverde, A, Armada, D, Dagnac, T, Llompart, M (15 June 2024). “Recycled tire rubber materials in the spotlight. Determination of hazardous and lethal substances.” Science of The Total Environment; (929), 172674.
https://www.sciencedirect.com/science/article/pii/S0048969724028213 27 Skoczyńska, E, Leonards, PEG, Llompart, M, de Boer, J (Aug 2021). “Analysis of Recycled Rubber:
Development of an Analytical Method and Determination of Polycyclic Aromatic Hydrocarbons and Heterocyclic Aromatic Compounds in Rubber Matrices.” Chemosphere. Vol. 276,130076 https://doi.org/10.1016/j.chemosphere.2021.130076
26 Perkins, AN, Inayat-Hussain, SH., Deziel, NC et al (Feb 2019). “Evaluation of Potential Carcinogenicity of Organic Chemicals in Synthetic Turf Crumb Rubber.” Environ Res; 169:163-172. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6396308/#!po=78.3333 25 California Environmental Protection Agency (19 May 2019). “Synthetic Turf Study.” Meeting of Scientific Advisory Panel. Office of Environmental Health Hazard Assessment. https://oehha.ca.gov/media/downloads/crnr/may2019turfappendicespdf.pdf Item 1
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playground surfaces clearly major point sources of PFAS and microplastic pollution that cannot go unaddressed.
Polycyclic Aromatic Hydrocarbons (PAHs):
Multiple studies have shown PAHs in crumb rubber. Research released in 2023 has shown the bioaccessibility of most of the 16 US EPA PAHs and 8 ECHA (European Chemicals Agency) PAHs in used tire crumb.32 Newly released research from Greece found that dust from used tire crumb playgrounds top coated with EPDM showed a six fold increase in exposure to petroleum based PAHs in dust that extended beyond the playground surface and onto surrounding concrete areas.33
Lead (Pb):
Lead and other heavy metals are found in used tire crumb and in playground surfacing.34 In PIP surfacing, which is heterogeneous, lead levels can vary widely, including hot-spots with significantly higher lead readings from one area to another. Used tire crumb is known to have leachable lead.
Numerous experts worldwide have stated there is no safe level of lead exposure:
“EPA and the Centers for Disease Control and Prevention (CDC) agree that there is no known safe level of lead in a child's blood. Taking action to reduce these exposures can improve outcomes. Lead is harmful to health, especially for children.” US EPA “There is no level of exposure to lead that is known to be without harmful effects. Lead exposure is preventable.” World Health Organization
“There is no safe level of lead exposure in children, with lasting decreases in cognition documented in children with blood levels as low as 5 micrograms per deciliter of lead in blood.” American Academy of Pediatrics
“It is also likely that when many more athletes are active on a field (e.g., 22 in a football game), the “cloud” of particulates that is generated may result in an elevated exposure relative to the particulates mobilized by a single occupant.” Drs. Stuart L Shalat and Alan Stern
“…data provide sufficient evidence to eliminate childhood lead exposure by banning all nonessential uses of lead and further reducing the allowable levels of lead in air emissions, house dust, soil, water, and consumer products.” 34 Gearhart, J (2021). Letter to Deputy Mayor of Education, Washington, DC: “Report on lead in pour in place (PIP) rubber playground at Janney Elementary School.” The Ecology Center, Ann Arbor, MI https://drive.google.com/file/d/1UfMzsVQ0EZKquGlnUKBgkspohIod9D-H/view?usp=drivesdk 33 Manoli, E, Fantidou, V, Kouras, A, Samara, C, (March 2025). Pre-print: “Polycyclic Aromatic Hydrocarbons in settled dust of playgrounds in Thessaloniki, Greece: Concentration levels and implications for childhood cancer risk. Environmental Research. https://doi.org/10.1016/j.envres.2025.121300
32 Armada, D, Martinez-Fernandez, A, Celeiro, M et al (20 Jan 2023). “Assessment of the bioaccessibility of PAHs and other hazardous compounds present in recycled tire rubber employed in synthetic football fields.” Science of The Total Environment; (857) 2, 159485. https://www.sciencedirect.com/science/article/pii/S0048969721076208 Item 1
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Pediatrician and researcher on lead, children’s health and environment, Dr. Bruce Lanphear
“No safe blood lead level in children has been identified. Children are especially at risk from lead because of their small size and developing brains. Lead exposure can affect nearly every system in the body. Even low levels of lead in blood have been shown to negatively affect a child’s intelligence, ability to pay attention, and academic achievement. Removing all sources of lead exposure is important before a child is harmed.” Centers for Disease Control (CDC).
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Phthalates:
Phthalates are used extensively in the manufacturing of plastics. They are in plastics in playground equipment and surfacing as well as in tires. Like PFAS, they have endocrine disrupting properties.35 Like lead, they also have neurotoxic effects. “Ortho-phthalates are diesters of phthalic acid and are the predomina[nt] type of phthalate used in commerce…They are high-production-volume chemicals used most often as a plasticizer in polyvinyl chloride (PVC) and other plastics.”36 As plasticizers, they are used in plastic toys, playground equipment, “natural rubber” and tire manufacturing.37 Use of phthalate-containing products is choosing to risk impairment of children's I.Q.s, their brains and their overall health.
Polyvinyl Chloride (PVC) Tiles:
PVC is used in the manufacturing of playground equipment and surfacing. PVC is not a benign material. Use of a PVC product would be willfully exposing children and the environment to one of the most toxic chemicals on the planet.
Parents and caregivers trust that if a product is on the market, that it has undergone rigorous testing and found to be safe. Nothing could be further from the truth, and polyvinyl chloride38 is a case in point that must not go unaddressed. Vinyl chloride monomer,39 used in the production of polyvinyl chloride, is a category 1 carcinogen40 and has been on the California Proposition 65 list since 1987.
Nearly 60% of PVC is chlorine. Production creates significant human and environmental concerns due to chlorinated dioxins, furans and carbon tetrachloride,41 even when there are low 41 Health Care Without Harm (Europe), (25 Jun 2021). “The polyvinyl chloride debate: Why PVC remains a problematic material.”
40 Fralish, MS, Poole, ND, Downs, JW (updated 12 Jun 2023). “Vinyl Chloride Toxicity.” National Library of Medicine. Matthew S. Fralish; Nicholas D. Poole; John W. Downs. https://www.ncbi.nlm.nih.gov/books/NBK544334/
39 Office of Health Hazard Assesment (2025). Proposition 65 list. “Vinyl Chloride.” CA EPA. https://oehha.ca.gov/media/downloads/proposition-65//p65chemicalslist.pdf 38 National Cancer Institute (updated June 2024). Vinyl Chloride. https://www.cancer.gov/about-cancer/causes-prevention/risk/substances/vinyl-chloride 37 Johannessen, C, Liggio, C, Zhang, X et al (Sep 2022), “Composition and transformation chemistry of tire-wear derived organic chemicals and implications for air pollution.” Atmospheric Pollution Research; 13(9), 101533
https://www.sciencedirect.com/science/article/pii/S1309104222002148 36 Engel, SM, Patisaul, HB, Brody, C (Apr 2021). “Neurotoxicity of Ortho-Phthalates:
Recommendations for Critical Policy Reforms to Protect Brain Development in Children.” Am J Public Health. 2021;111(4): 687–695.
https://doi.org/10.2105/AJPH.2020.306014
35 Wang, Y, Qian, H, (18 May 2021). “Phthalates and Their Impacts on Human Health.” Healthcare (Basel); 9(5), 603.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8157593/
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levels of exposure. It wasn’t until March 2024 that the United States banned use of asbestos in chlorine.42 PVC playground tiles and mats also contain phthalates and per- and polyfluoroalkyl substances (PFAS).
“Various PVC additives also have hazardous properties and, therefore when emitted, can pose a threat to the environment and human health. PVC is considered as the most environmentally damaging plastic and one of the most toxic substances for inhabitants of our planet. From cradle to grave, the PVC lifecycle (production, use, and disposal) results in the release of toxic, chlorine-based chemicals, and it is one of the world’s largest dioxin sources. These toxins build up in water, air, and food chains. They cause severe health problems, including cancer, immune system damage, and hormone disruption. Everyone has measurable levels of chlorinated compounds (toxins) in their bodies.”43
“PVC…initial manufacturing did not produce a stable material, unless stabilizing chemicals were added, such as lead carbonate. Without these, PVC easily degrades and releases corrosive hydrogen chloride if heated or exposed to sunlight.
Further, rigid PVC could only be made moldable and flexible by the addition of plasticizers, phthalates, used in the past to plasticize celluloid.”44 ”Traditional methods for the storage and incineration of PVC waste lead to the release weight, highly stable covalent bonds, and hydrophobic surface properties, creating a base of harmful chlorinated compounds: hydrogen chloride and chlorine‐containing dioxins huge environmental problem during its production and disposal. PVC waste is highly resistant to decomposition in the environment but often releases harmful chlorinated compounds that negatively affect the health of organisms and the ecosystem. PVC is classified as a substance with strong mutagenic and carcinogenic properties, and it is more toxic than other plastics due to the presence of chlorine atoms in it.”42
In addition to the chemicals in PVC tiles and mats, highly toxic glues, adhesives and binders may be incorporated during the manufacturing process, to secure interlocking tiles or mats, or to secure the tiles to closed cell foam or foamed XLPE (cross-linked polyethylene) underlayment pad that may be used with this or other synthetic surfacing. 44 Wagner, M, Monclús, L, Arp, HPH et al (Mar 2024). “State of the science on plastic chemicals:
Identifying and addressing chemicals and polymers of concern.” PlastChem, Norway. https://plastchem-project.org
43 Kudzin, MH, Piwowarska, D, Festinger, N, Chruściel, JJ (2024). “Risks Associated with the Presence of Polyvinyl Chloride in the Environment and Methods for its Disposal and Utilization.” MDPI; 17(1), 173 www.mdpi.com/1996-1944/17/1/173
42 US EPA (18 Mar 2024). “Biden-Harris Administration finalizes ban on ongoing uses of asbestos to protect people from cancer.”
https://www.epa.gov/newsreleases/biden-harris-administration-finalizes-ban-ongoing-uses-asbestos-prote ct-people-cancer
https://noharm-europe.org/sites/default/files/documents-files/6807/2021-06-23-PVC-briefing-FIN AL.pdf
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Plastics, including PVC and polyethylene, will degrade, will leach toxic chemicals to air, water and soil, will heat the environment and contribute to climate change, will form microplastics and will release their toxic payloads into the very air we breathe, the water we drink and the food we eat.
The US Environmental Protection Agency (EPA) has begun the process to ban PVC.45,46 PVC tile used for playgrounds only has a six-year warranty, suggesting it may degrade rapidly in the environment, releasing micro- and nanoplastics to air, water and soil during its short “useful” life, after which time it will need to be landfilled, and likely in a hazardous waste landfill due to its toxicity. Yet another incredibly bad choice, on taxpayer dollars, for a product that harms not only children, but the environment.
46 Le Coz, E (14 Dec 2023). “EPA begins formal review of 5 toxic chemicals, including one in Ohio train derailment.” USA Today.
https://www.usatoday.com/story/news/investigations/2023/12/14/epa-begins-process-to-potentially-ban-vi nyl-chloride-used-in-pvc/71923363007/
45 US EPA (13 Dec 2023). “EPA Begins Process to Prioritize Five Chemicals for Risk Evaluation Under Toxic Substances Control Act.”
https://www.epa.gov/newsreleases/epa-begins-process-prioritize-five-chemicals-risk-evaluation-under-toxi c-substances
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Microplastics:
Research by the Department of Civil and Environmental Engineering, University of California, Los Angeles, and the Moore Institute for Plastic Pollution Research, Long Beach, found “Children's playgrounds contain more microplastics than other areas in urban parks.”24 In addition to the CA Statewide Microplastics Strategy47, CA DTSC recently announced its intent to add Microplastics to the Candidate Chemicals List.48 Microplastics are released from plastic playground structures, synthetic surfacing materials, and hypar sails used for shade.
Microplastics not only leach chemicals, including PFAS, they adsorb other chemicals and bacteria, posing particular risk to the food chain. Even the best BMPs (Best Management Practices) will capture only a small percentage of the microplastics and virtually none of the PFAS and other toxic chemicals from plastic elements. Drainage systems are not expensive granulated activated carbon (GAC) filters.
Microplastics have been found in 1,288 marine species and 277 terrestrial and freshwater species.49 They have even been found in air exhaled by dolphins via their blowholes.50 PFAS from micro- and nanoplastics have been found in sea spray.51 51 Gribkoff, E (21 Dec 2021). “Sea spray is belching toxic chemicals back on land: Study links PFAS contamination in coastal air to breaking waves.” Science Advisor Newsletter. https://www.science.org/content/article/sea-spray-belching-toxic-chemicals-back-land 50 Dziobak, MK, Fahlman, A, Wells, RS (16 Oct 2024). “First evidence of microplastic inhalation among free-ranging small cetaceans.” PlosOne.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0309377 49 Jambeck, JR, Walker-Franklin, I (16 Jun 2023). “The impacts of plastics’ life cycle.” One Earth; 6(6), 600-606
https://doi.org/10.1016/j.oneear.2023.05.015
48 Safer Consumer Product Program (2023). “Proposed Addition to the Candidate Chemicals List:
Microplastics.” California Department of Toxic Substances Control. https://dtsc.ca.gov/scp/candidate-chemical-list_microplastics/ 47 California Senator Portantino (20 Sept 2018). Ocean Protection Council: Statewide Microplastics Strategy. Chapter 3.2; Section 35635; Division 26.5 of the Public Resources Code, relating to pollution. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1263 Item 1
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Natural Playgrounds;
Natural playgrounds have significant benefits over plastic playgrounds:
● Significantly reduce or eliminate risk of toxic and cancer causing chemicals to humans and the environment from plastic components.
● Provide a significantly cooler environment.
● Are consistent with the National Parks and Recreation Association (NRPA) Three Pillars.52,53
● Have significant physical and mental health benefits54:
o Boosts immunity.55
o Reduces asthma56 and symptoms of Attention Deficit Hyperactivity Disorder (ADHD).57 o Mitigate aggressive behavior in adolescents.58
o Significantly reduce the growing risk of psychiatric disorders59 and suicide mortality. 60 60 Asri, AJ, Tsai, HJ, Wong, PY et al (4 Jul 2022). “Examining the Benefits of Greenness on Reducing Suicide Mortality Rate: A Global Ecological Study.” Front. Public Health, Sec. Environmental Health and Exposome;10, 902480.
59 Engemann, K, Pedersen, CB, Arge, L, Svenning, JC (25 Feb 2019). “Residential green space in childhood is associated with lower risk of psychiatric disorders from adolescence into adulthood.” PNSA; 116 (11) 5188-5193
https://doi.org/10.1073/pnas.1807504116
58 Younan, D, Tuvblad, C, Lianfa, L et al (2016). “Environmental Determinants of Aggression in Adolescents: Role of Urban Neighborhood Greenspace.” J Am Acad Child Adolesc Psychiatry; 55(7):591–601.
https://pubmed.ncbi.nlm.nih.gov/27343886/
57 Thygesen, M, Engemann, K, Gitte, JH et al (22 Dec 2020). “The Association between Residential Green Space in Childhood and Development of Attention Deficit Hyperactivity Disorder: A Population-Based Cohort Study.” Environmental Health Perspectives; 128(12). https://doi.org/10.1289/EHP6729
56 Hartley, K, Ryan, P, Brokamp, C, Gillespie, GL (3 Jan 2020). “Effect of greenness on asthma in children: A systematic review.” Public Health Nurs. 37(3):453–460. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9292730/
55 Franco, A, Robson, D (10 Oct 2022). “How mud boosts your immune system.” British Broadcastings Corp. (BBC).
https://www.bbc.com/future/article/20220929-how-outdoor-play-boosts-kids-immune-systems 54 Zhang, Y, Mavoa, S, Zhao, J (11 Sep 2020). “The Association between Green Space and Adolescents’ Mental Well-Being: A Systematic Review.” Int J Environ Res Public Health; 17(18):6640. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7557737/
53 National Recreation and Parks Association (n.d.). “Our Three Pillars: Health and Wellbeing, Equity, Environmental Resilience.”
https://www.nrpa.org/our-work/Three-Pillars/
52 National Recreation and Parks Association (n.d.). “Role of Parks and Recreation in Conservation.” https://www.nrpa.org/our-work/Three-Pillars/role-of-parks-and-recreation-in-conservation/#:~:text=Clean, %20green,%20and%20accessible%20parks%20and%20open%20spaces,air,%20and%20enabling%20th e%20conservation%20of%20natural%20resources
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o Enhance behavioral self-regulation61 and academic performance.62 o Foster cognitive development,63 imagination, creativity64 and appreciation for nature. o May reduce gun violence and vandalism.65
● Reduce taxpayer liability for high installation, maintenance and replacement costs for items that pose risk to children and others.
● May reduce liability risks for injuries, violations of the U.S. Clean Water Act.66 66 US EPA (updated 29 Jan 2025). “National Pollutant Discharge Elimination System (NPDES).” https://www.epa.gov/npdes
65 Branas, CC, South, E, Kondo, MC et al (2018). “Citywide cluster randomized trial to restore blighted vacant land and its effects on violence, crime, and fear.” Proceedings of the National Academy of Sciences (PNAS); 115(12), 2946–2951
https://doi.org/10.1073/pnas.1718503115
64 Wojciehowski, M, Ernst, J (2018). “Creative by Nature: Investigating the Impact of Nature Preschools on Young Children’s Creative Thinking.” The International Journal of Early Childhood Environmental Education; 6(1), 3.
https://files.eric.ed.gov/fulltext/EJ1193490.pdf
63 Weir, K (1 Apr 2020). “Nurtured by nature: Psychological research is advancing our understanding of how time in nature can improve our mental health and sharpen our cognition.” American Psychological Association; 51(3), 50.
https://www.apa.org/monitor/2020/04/nurtured-nature
62 Leung, WTV, Tam, TYT, Pan, WC, Wu, CD (Jan 2019). “How is environmental greenness related to students' academic performance in English and Mathematics?” Landscape and Urban Planning; vol. 181, 118-124.
https://www.sciencedirect.com/science/article/pii/S0169204618310569 61 McCormick, R. (2017). Does access to green space impact the men- tal well-being of children: A systematic review. Journal of Pediatric Nursing, 37, 3–7. https://doi.org/10.1016/j.pedn.2017.08.027
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Elementary school in Watts, Los Angeles67
67 UCLA Luskin Center (May 2023). Policy Brief. “Protecting Californians with Heat-Resilient Schools.” https://innovation.luskin.ucla.edu/wp-content/uploads/2023/05/Protecting-Californians-with-Heat-ResilientSchools.pdf Item 1
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Heat:
Plastics get very hot and pose a risk for thermal burns, sometimes significant enough to require hospitalization. At a surface temperature of 118°F a first-degree thermal burn occurs in 15 minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.68 High temperatures pose a serious risk for heat illness. One of the predisposing factors for heat illness are prescription drugs for treatment of attention deficit hyperactivity disorder, ADHD, which can be caused by PFAS chemicals found in plastics and medications.69,70 Children are not small adults. They are more readily impacted by heat illness and heat stroke due to:71
● Heat production – Children have higher metabolic rates than adults which leads to higher heat production.
● Body surface area – Younger children absorb more heat because they have a greater body area to body mass ratio. For older children and teens, increased body fat and low fitness levels are contributing factors.
71 UpToDate. “Heat Stroke in Children: Pathophysiology.” https://www.uptodate.com/contents/heat-stroke-in-children?search=Heat%20stroke%20in%20children&so urce=search_result&selectedTitle=1%7E51&usage_type=default&display_rank=1#H4 70 UpToDate. “Medical Risk Factors for Heat Illness in Children.” https://www.uptodate.com/contents/image?imageKey=EM%2F73292&topicKey=EM%2F6596&source=se e_link
69 Forns, J, Verner, MA, Iszatt, N (6 May 2020). “Early Life Exposure to Perfluoroalkyl Substances (PFAS) and ADHD: A Meta-Analysis of Nine European Population-Based Studies.” Environ Health Perspect; 128(5):57002.
https://ehp.niehs.nih.gov/doi/10.1289/EHP5444
68 Moritz AR, Henriques FC Jr (1947). Original source. “Studies of thermal injury II: The relative importance of time and surface temperature in the causation of cutaneous burns.” Am J Pathol.; 23:
915-941.
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Safe Healthy Playing Fields Inc.
www.safehealthyplayingfields.org
12 March 2025
Memorial Park Redevelopment and Expansion Project
Santa Monica City Council, Environmental Planning and Recreation and Arts Departments:
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 support of full and meaningful environmental impact review (EIR) under the California Environmental Quality Act (CEQA). Full transparency, disclosure, and a commitment to true environmental safety and to all who would be exposed to the toxic and carcinogenic chemicals known to exist in this fossil fuel-based petrochemical plastic product, whether on playing fields or used in landscaping.1,2 A full EIR is necessary due to multiple factors, including, but not limit to:
● Significant environmental impacts that cannot be mitigated ● Unusual circumstances
● Cumulative effects
● Greenhouse gas emissions
● Hydrology/water impacts
● Viable alternatives
● Awareness of legislative and regulatory schemes
● Awareness of the current state of science
Additionally, the use of synthetic is in direct conflict with many of Santa Monica’s own ordinances.
2 Kassotis, C (23 Sep 2024). “Endocrine and cardiometabolic toxicity of artificial turf associated materials.” Video of presentation at NYU Langone Health symposium on plastics research. https://www.youtube.com/watch?v=q8MDXyQKnFA
1 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111), 104562. https://doi.org/10.1016/j.etap.2024.104562
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Synthetic turf is most often made from low density polyethylene, the same material as straws and plastic bags. It is the most globally produced and discarded fossil fuel-based petrochemical plastic.
As calculated by the Martha’s Vineyard Conservancy, a single regulation sized plastic playing field is the equivalent of 3.2 million plastic bags, or 42 million plastic straws.3 Microplastics:
California’s Statewide Microplastics Strategy - Senate Bill No.1263 (Chapter 609), was enacted in 2018.4 In addition, CA DTSC has announced its intent to add Microplastics to its Candidate Chemicals List for regulation.5
A 2017 study found that a single synthetic turf field loses 0.5 to 0.8% of its blades annually. This estimate is ten times lower than a previous Danish study (0.8 kg/m2).
This equates to 2,000 to 3,000 pounds of microplastic blade loss per year per field.6,7 Newer playing fields that do not require infill poured on top of the synthetic carpet are 7 CA DTSC (27 Aug 2024). Slide deck, presentation on Candidate Chemicals in Artificial Turf. CA EPA. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/09/Artificial-Turf-Workshop-Slides_DTSC_Accessibl e.pdf
6 Hann, S et al (2018). “Investigating Options for Reducing Releases in the Aquatic Environment of Microplastics Emitted by (but not Intentionally Added in) Products.” Eunomia, United Kingdom. https://www.eunomia.co.uk/case_study/measuring-impacts-of-microplastics/ 5 Safer Consumer Product Program (2023). “Proposed Addition to the Candidate Chemicals List:
Microplastics.” California Department of Toxic Substances Control. https://dtsc.ca.gov/scp/candidate-chemical-list_microplastics/ 4 Senate Bill No. 1263 (2018). “CHAPTER 609: An act to add Chapter 3.2 (commencing with Section 35635) to Division 26.5 of the Public Resources Code, relating to pollution. State of California. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1263 3 Doyle, M, Slavin, D, Thomson, R (29 Jan 2019). “Numbers flawed in turf vs. grass debate.” Martha’s Vineyard Times.
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more densely woven, may have double backing,8
and have the potential for significantly
greater microplastic blade and carpet backing loss to the environment.
Microplastic synthetic turf blades have been found in Lake Tahoe, where researchers found high levels of polyethylene and polypropylene in the lake and “…recorded plastics concentrations more than three times higher than those sampled using a similar method in the North Atlantic subtropical gyre.”
9,10,11
Synthetic turf fibers have been found in the world’s oceans, ranging from 12 to over 15 percent of the microplastics found, as reported by researchers in Spain, China, Japan, Australia and Canada. Synthetic turf blades represent as much as 25% of microplastics in surface waters.12 This research lead to the California Coastal Commission's decision to not allow synthetic turf at UC Santa Barbara (13 Dec 2023) and stating synthetic turf is not superior to natural grass and is not sustainable.
12 De Haan, WP, Quintana, R, Vilas, C, Cózar, A et al (1 Oct 2023).“The dark side of artificial greening:
Plastic turfs as widespread pollutants of aquatic environments.” Environmental Pollution; 334, 122094. https://www.sciencedirect.com/science/article/pii/S0269749123010965?via%3Dihub 11 Personal email communication from research staff at Tahoe Environmental Research Center. Lake Tahoe Email
10 Spencer, C (2023). “Lake Tahoe has higher concentration of microplastics than ocean trash heap.” LA Times.
https://www.latimes.com/california/story/2023-07-14/lake-tahoe-troubling-concentration-microplastics 9 Schultz, Madison. 2022. “UC Davis Environmental Research Center fundamental at Lake Tahoe.” Sierra Sun. Accessed 26 Oct 2023.
https://www.sierrasun.com/news/uc-davis-environmental-research-center-fundamental-at-lake-tahoe/ 8 TenCate Pivot (2024). Face weght of 120 ounces per yard2, double backing, total weight 147.5 ounces per yard2.
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“Section 21080.5(d)(2)(A) of CEQA prohibits the Commission from approving a proposed development if there are feasible alternatives or feasible mitigation measures available that would substantially lessen any significant adverse effect which the activity may have on the environment.
For the reasons discussed in this report, the Commission has conditioned the NOID to require design and implementation of Final Revised Project Plans that do not include the installation of artificial turf.”13 Additional loss of microplastics from the backing (approximately 438 pounds/per field annually), exclusive of the underlayment pad and infill.14
Microplastics both leach and adsorb toxic chemicals and bacteria in the environment, putting the food chain at risk.
With virtually all plastic ever made still in existence, the impact on the environment, ecosystems and biodiversity loss from the chemical leachate and microplastics is immense. From zooplankton, krill, whales, bees, and terrestrial animals of the Americas, macro-, micro- and nanoplastics are impacting aquatic and wildlife, and even our pets. Synthetic turf and microplastics have caused a decrease in bird populations, accumulation of microplastics on bees, and negatively impacts ocean habitats and biodiversity both above and below ground.
Research from 2021 estimated that >1500 species have ingested microplastics.15 Found from the peak of Mount Everest, to the depths of the Mariana trench, microplastics and now recently, been found in high levels in air exhaled by dolphins via their blowholes.16 It is estimated that roughly one million seabirds and 100,000 marine mammals are killed annually from plastic in our oceans.
In its 2024 Report, the World Wildlife Fund reports a loss of 73% of wildlife populations in the period from 1970 to 2020.17 From cradle to grave, fossil fuel extraction to production, 17 World Wildlife Federation (2024). “Living Planet Report: 2024. Nature is Disappearing: The Average Size of Wildlife Populations Has Fallen By a Staggering 73%.” https://livingplanet.panda.org/en-US/
16 Dziobak, MK, Fahlman, A, Wells, RS (16 Oct 2024). “First evidence of microplastic inhalation among free-ranging small cetaceans.” PlosOne.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0309377 15 Santos, RG, Machovsky-Capuska, GE, Andrades, R (2021). “Plastic Ingestion as an Evolutionary Trap:
Toward a Holistic Understanding.” Science: 373, 56–60. https://pubmed.ncbi.nlm.nih.gov/34210877/ 14 Kole, PJ, Van Belleghem, F, Stoorvogel, JJ, Ragas, A, Löhr, AJ (10 Dec 2023). “Tire granulate on the loose: How much escapes turf? A systematic literature review.” Science of The Total Environment; (903)166221.
https://doi.org/10.1016/j.scitotenv.2023.166221
13 California Coastal Commission (13 Dec 2023). “Notice of Impending Development UCS-NOID-0002-23 (Baseball Stadium Turf).”
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf Item 1
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manufacturing, use and disposal, plastics impact healthy soil, water, ecosystems, human health and wildlife.
Any commitment to not use used tire crumb infill or other microplastic infill poured on top of the plastic turf carpet is a distraction meant for all to believe it is the only concern related to synthetic turf. Often sourced outside of the US, plant based synthetic turf infills can contain pesticides, PFAS, heavy metals and more. Because they add excess nutrients to soil and water, they have been implicated in increased frequency and severity of toxic algal blooms.18 Drainage systems, with or without filters, nor straw wattles or catchment basins, will solve the issues of micro-, meso-, or nanoplastics. These plastic fragments readily loft into the air and can travel for miles and reloft over and over. The same applies to these plastic fragments in water, carrying their toxic payloads with them.19
Microplastics not only leach chemicals, including endocrine disrupting forever PFAS, they adsorb other chemicals and bacteria, posing particular risk to the food chain. Even the best BMPs (Best Management Practices) will capture only a small percentage of the microplastics and virtually none of the nanoplastics, PFAS and other toxic chemicals from synthetic turf.
Drainage systems are not expensive granulated activated carbon (GAC) filters. 19 Lambert, S, Vercauteren, M, Catarino, AI et al (15 June 2024). “Aerosolization of micro- and nanoplastics via sea spray: Investigating the role of polymer type, size, and concentration, and potential implications for human exposure.” Environmental Pollution; (351), 124105 https://www.sciencedirect.com/science/article/abs/pii/S0269749124008194 18 US EPA (1 Feb 2024). Nutrients and Harmful Algal Blooms Research. https://www.epa.gov/water-research/nutrients-and-harmful-algal-blooms-research Item 1
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Toxic Chemicals:
As outlined in the 27 Aug 2024 presentation by the California Dept. of Toxic Substances Control (DTSC), there are multiple chemical classes of concern in synthetic turf.20 Some of these chemicals include (not comprehensive):
● PFAS21,22,23,24,25
● Phthalates26,27,28
28 IE DuPont de Nemours (2015).
https://patents.justia.com/patent/9017788
27 Safer Consumer Products Program (Aug 2024). “Background Document on Candidate Chemicals in Artificial Turf.” Dept. of Toxic Substances Control, California Environmental Protection Agency. https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicalsin-Artificial-Turf.pdf 26 Ryan-Ndegwa, S, Zamani, R, Martins, T (17 Dec 2024). “Exploring the Human Health Impact of Artificial Turf Worldwide: A Systematic Review.” Environ Health Insights; (18),11786302241306291 https://doi.org/10.1177/11786302241306291
25 Multi-organizational fact sheet (2022). “PFAS polymers pose serious health and environmental threats.” https://drive.google.com/file/d/1fJDsNTIPp-YMT_7aQ0TDvTaLg2lB5PMA/view?usp=drivesdk 24 EI DuPont de Nemours (2013)
https://patents.justia.com/patent/8568874
23 Dept. of Toxic Substances Control (27 Aug 2024). “Background Document on Candidate Chemicals in Artificial Turf.” California EPA.
https://dtsc.ca.gov/wp-content/uploads/sites/31/2024/07/Background-Document-on-Candidate-Chemicalsin-Artificial-Turf.pdf 22 Woelke, D (Nov 2024). Compilation of PFAS leachate testing from synthetic turf results.
PFAS leachate from synthetic turf
21 Glüge, J, Scheringer, M, Cousins, IA, DeWitt, JC et al (30 Oct 2020). “An overview of the uses of perand polyfluoroalkyl substances (PFAS).” Environ Sci Process Impacts;22(12):2345–2373. https://pmc.ncbi.nlm.nih.gov/articles/PMC7784712/
20 Dept. of Toxic Substances Control. (27 Aug 2024). California EPA.
Presentation Slides
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● Latex (including styrene butadiene)29,30,31,32
32 Staff writer (3 Jul 2024). “Artificial Turf Fields.” Institute For Climate Change, Environmental Health, and Exposomics. Mt. Sinai ICAHN School of Medicine.
Exposomic Research
31 Sick, S (2021). Patent
https://patents.justia.com/patent/10968565
30 Sick, S (2017). Patent application
https://patents.justia.com/search?q=FLOOR+PAVEMENT+STRUCTURE+WITH+GEL+L 29 Tomarin, SA (1984). Patent
https://patents.justia.com/patent/4497853
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● Naptha18,,33,34
● Siloxanes35,36
● Talc37,38
● Di/Isocyanates39
● Formaldehyde29
● Fungicides26
● Flame retardants26
● Coal fly ash26
● Anti-Microbial agents40,41,42
● Dibutyltin Ethylene glycol43
43 Sick (2017)
https://patents.google.com/patent/WO2018122346A1
42 Verdú, I, Gonzalez-Pleiter, M, Leganés, F et al (Mar 2021). “Microplastics can act as vector of the biocide triclosan exerting damage to freshwater microalgae.” Chemosphere. https://www.sciencedirect.com/science/article/abs/pii/S0045653520333907 41 Triclosan Fact Sheet. BioMonitoring California.
https://biomonitoring.ca.gov/sites/default/files/downloads/TriclosanFactSheet.pdf 40 Dow Chemical (2017).
https://patents.justia.com/patent/20190078235
39 Sick, S (2021) patent
https://patents.justia.com/patent/11180894
38 Dow Global Technologies, Inc (2008) patent application https://patents.justia.com/patent/20100279032
37 Sick, S (2015) patent
https://patents.justia.com/patent/10968565
36 Dow Global Technologies, Inc (2015) patent
https://patents.justia.com/patent/9040627
35 Ferreira T, Homem V, Cereceda-Balic F et al (2024). “Are volatile methylsiloxanes in downcycled tire microplastics? Levels and human exposure estimation in synthetic turf football fields.” Environ Sci Pollut Res Int. 10.1007/s11356-024-31832-1
https://link.springer.com/article/10.1007/s11356-024-31832-1 34 Modern Fibers Inc (1984) patent
https://patents.justia.com/patent/4617208
33 Sick, S (2017) patent application
https://patents.justia.com/patent/8568874
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● UV stabilizers30,44.45
● Anti-Static Treatments30
● Colorants
All synthetic turf tested by academic institutions and independent third party laboratories using proper methods, techniques and reporting limits have found PFAS in synthetic turf.46,47 PFOS was found on the hands of young soccer players who played on synthetic turf in a small pilot study in San Diego in the summer of 2023.48 That study is currently being replicated by the Kassotis Lab, Wayne State University, with 50 student athletes and multiple playing fields.
Of high significance, a study done by the Kassotis Lab, in conjunction with The Ecology Center (Ann Arbor, MI), “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials” published in the October 2024 edition of Environmental Toxicology and Pharmacology, demonstrates the cytotoxic effects of chemicals in synthetic turf to endocrine organs and cardiac development and function. This study also demonstrates the importance of looking at combined chemical exposures associated with a given product.49 No one is ever exposed to one chemical- certainly not with plastics and definitely not with synthetic turf. 49 Siegela, KR, Murraya, BR, Gearhart, J, Kassotis, CD (2024). “In vitro endocrine and cardiometabolic toxicity associated with artificial turf materials.” Environmental Toxicology and Pharmacology; (111), 104562. https://doi.org/10.1016/j.etap.2024.104562
,
48 Amenabar, T (Mar 2024). “Study eyes safety of turf fields for kids: Scientists team up with San Diego Surf soccer club to discover if ‘forever chemicals’ pose risk.” San Diego Union Tribune, originally published in the Washington Post.
https://enewspaper.sandiegouniontribune.com/infinity/article_popover_share.aspx?guid=7f93edcb-cd5b-4 f9d-b8e4-ed57343daefc&share=true
47 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf:
Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of Massachusetts, Lowell.
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2 0Other%20Tests%20Aug%202024_tcm18-386957.pdf
46 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University of Notre Dame.
https://doi.org/10.7274/bg257d30j3m
45 Awonaike, B, Lei, YD, Parajulee, A, Wania, F (1 Dec 2021). “Phase partitioning, transport and sources of Benzotriazole Ultraviolet Stabilizers during a runoff event.” Water Research X; (13),100115 https://www.sciencedirect.com/science/article/pii/S2589914721000281#:~:text=High%20levels%20of%20 UV328%20and%20UV234%20were,a%20sink%20than%20a%20source%20of%20BT%2DUVs 44 International Pollutant Elimination Network.“Communications on Recent Research: Recent Research on UV-328 Further Proves its Potential to Undergo Long-Range Transport, Bioaccumulate, and Cause Harm.”
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With chemicals of concern in both children’s products and synthetic turf currently under review by the California Department of Toxic Substances ControlCA (DTSC), it is reasonable to expect markedly lower acceptable limits for PFAS and additional chemicals.
If the industry were able to eliminate PFAS from its products some day, it would still be plastic, with myriad toxic, carcinogenic and hazardous chemicals.
Regulation in process in CA!
Early chemgrass, made without PFAS, was brittle. The synthetic turf industry has had 60 years to self-regulate. Were it capable of doing so, it would not be under review for regulation by DTSC at this time.
The California Department of Toxic Substances Control has determined it will be bringing synthetic turf under regulation for per- and polyfluoroalkyl substances (PFAS) that have been found in 100% of synthetic turf tested by academic, non-profit organizations and independent testing in commercial laboratories to date.50,51 They are also reviewing information on flame retardants, endocrine disrupting and neurotoxic phthalates, antimicrobials, colorants, and more, and will make additional announcements at a future date.52,53,54,55,56 Regulation will have major implications regarding disposal of these fossil fuel-based petrochemical products as well as the ability to replace these fields in the future.
CA DTSC PFAS fact sheet
56 DTSC (27 Aug 2024). CalSAFER website
55 DTSC (27 Aug 2024). Presentation Slides
54 DTSC (27 Aug 2024). Meeting Agenda
53 DTSC (27 Aug 2024). Background Document
52 DTSC (27 Aug 2024). “Virtual Workshop on Candidate Chemicals in Artificial Turf” Meeting Recording 51 Pollard, L, Massey, R (Aug 2024). “Per- and Poly-fluoroalkyl Substances (PFAS) in Artificial Turf: Academic, municipal, and other testing efforts.” Lowell Center for Sustainability, University of Massachusetts, Lowell.
https://www.uml.edu/docs/PFAS%20in%20Artificial%20Turf%20-%20Academic%20Municipal%20%26%2 0Other%20Tests%20Aug%202024_tcm18-386957.pdf
50 Whitehead, H. D. (2023). “Development of Analytical Methods for Highly Selective and Sensitive Analytical Analysis of Compounds Relevant to Human Health and the Environment.” Version 1. University of Notre Dame.
https://doi.org/10.7274/bg257d30j3m
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Based on the current state of science, installation of synthetic turf is knowingly and willfully choosing to expose children, adults, bystanders, maintenance workers, vulnerable populations, wild and aquatic life to an increased risk of disease, disability, and even death due to the toxic and carcinogenic chemicals found in, and leaching to air, water and soil from synthetic turf.
In addition to CA DTSC, the City of Los Angeles is working on a highly supported ordinance that would ultimately ban synthetic turf.57
The cities of Millbrae and San Marino have enacted ordinances banning synthetic turf under SB676- Allen (2023)58 and additional cities are currently considering taking action.
In addition to the CA Statewide Microplastics Strategy - Senate Bill No.1263 (Chapter 609, 2018),59 CA DTSC has announced its intent to add Microplastics to the Candidate Chemicals List.60
Impervious surfacing:
“Grass doesn’t waste water. People do!”
Dr. James Baird, UC Riverside Turfgrass Management Program
Plastic turf does not save water:Synthetic turf requires approximately 989 gallons of water to produce 1 square meter of turf61 estimated to be the equivalent of watering a square meter of natural grass for 18 years. Additional water is required for cooling to a safe temperature for playing as well as for cleaning pollution, bodily fluids (like blood and vomit), animal waste, mold, bacteria and more from plastic turf and is often a condition of warranty.
Per various maintenance manuals, cleaning of synthetic turf requires the use of toxic chemicals, which will be added to the toxic run-off that leaches from the plastic to soil, air and water. 61 Waterwise UK. “How to save water: Artificial Grass’s Footprint.” https://www.waterwise.org.uk/save-water/
60 Safer Consumer Product Program (2023). “Proposed Addition to the Candidate Chemicals List:
Microplastics.” California Department of Toxic Substances Control. https://dtsc.ca.gov/scp/candidate-chemical-list_microplastics/ 59 Senate Bill No. 1263 (2018). “CHAPTER 609: An act to add Chapter 3.2 (commencing with Section 35635) to Division 26.5 of the Public Resources Code, relating to pollution. State of California. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1263 58 Allen, B (8 Oct 2023). “Allen. Local ordinances and regulations: drought-tolerant landscaping An act to amend Section 53087.7 of the Government Code, relating to local government. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB676 57 City of Los Angeles (2024-present). “Synthetic Grass / Artificial Turf / Polyflouroalkyl Substances (PFAS) / Forever Chemicals / Health and Environmental Risks / Drought-Friendly Landscaping.” https://cityclerk.lacity.org/lacityclerkconnect/index.cfm?fa=ccfi.viewrecord&cfnumber=24-0602 Item 1
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Synthetic turf is an impervious, or impermeable, surface, despite what the industry tells you.
The US EPA and the State of California are clear on this issue:62 “...areas such as gravel roads...that will be compacted through design or use to reduce their impermeability.” It further has 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.”
“Pollutants from aerial and terrestrial sources accumulate on impervious surfaces until runoff from a precipitation event carries sediment, nutrients, metals, and pesticides into stormwater drains and directly to local water bodies. As impervious surfaces increase, stormwater runoff increases in quantity, speed, temperature, and pollutant load. When impervious surfaces reach 10–20% of local watershed area, surface runoff doubles and continues to increase until, at 100% impervious surface coverage, runoff is five times that of a forested watershed. Excessive stormwater runoff also increases the potential for flooding.” US EPA Impervious Surface Fact Sheet63
As impervious surfaces, accumulation of particulate matter, jet and leaded AVgas fuel from the multiple flight paths over Santa Monica bring even more need for concern. 63 US EPA (2020). “EnviroAtlas: Fact Sheet, Percent Impervious Area.” https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/ESN/PercentImperviousArea.pdf 62 US EPA, MS4 General Permit Appendix A, Definitions, Abbreviations and Acronyms, https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-a-2016-ma-sms4-gp.pdf Item 1
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Toxic runoff from synthetic turf contributes 27,000 gallons per one inch of rain per acre of plastic.64 It is abundantly clear that, given the amount of synthetic turf currently installed in Santa Monica’s parks alone, exclusive of schools, residential and commercial applications, that a massive amount of toxic runoff from synthetic fields is contaminating soil, surface, ground and, eventually, the city’s drinking water and even the ocean.
Based on Historic Belmont Park and Airport Park synthetic turf fields alone, and nearly 57 inches of rainfall at San Monica Airport since 2022, these fields have contributed 8,233,650 gallons of toxic runoff to surface and groundwater, and the ocean. The Memorial Park Project would likely more than triple this amount.
How much PFAS is running off of Santa Monica’s plastic grass playing fields?65 65 Peaslee, GF (27 Aug 2024), Slide deck presentation at DTSC: “Chemicals of Concern in Syntheit Turf.” Peaslee, GF. CA DTSC Aug 2024
64 Cotrone, V (undated). “The Role of Trees and Forests in Healthy Watersheds: Managing stormwater, reducing flooding, and improving water quality.” Penn State Extension. https://extension.psu.edu/the-role-of-trees-and-forests-in-healthy-watersheds Item 1
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Heat:
Synthetic turf readily reaches temperatures of 160-180F, regardless of infill type, and has been known to reach over 220F. At a surface temperature of 118°F, a first-degree thermal burn occurs in 15 minutes, becoming a 3rd degree burn (full skin-thickness) in 20 minutes; at a temperature of 140°F, 1st degree burns occur in 3 seconds, and 3rd degree burns in 5 seconds.66 Children have required admission to burn and intensive care units treatment of burns sustained on plastic playing surfaces.
An estimated 9,000 student athletes are treated for exertional heat illness each year.67 The reduced functional level created by heat from synthetic surfaces, even at reasonable ambient temperatures can contribute to injuries due to compromised functional level.
As the planet heats up, athletes are increasingly impacted by heat related illness by playing on synthetic surfaces. Deaths among high school football players from heat stroke doubled from 2015 to 2017 when compared to the 5 preceding years.68 Football players are eleven times more likely to suffer a heat related illness. Playing on synthetic turf is a contributing factor.
There is an increasing incidence of heat stroke amongst athletes. Mortality is high and if a child survives heat stroke, their risk for recurrence of heat illness is increased.69 As the body heats, it is susceptible to absorbing more chemicals. PFAS have been shown to be absorbable via the skin.70
A reduction in hours of use will be increasingly impacted by:
● Climate change- extreme heat and atmospheric river events ● AB 1653- Intercollegiate athletic programs emergency action plans: heat illness:
guidelines71
71 State of California (8 Oct 2023). “Assembly Bill No. 1653; CHAPTER 589. An act to amend Section 35179.4 of, and to add Section 35179.8 to, the Education Code, relating to interscholastic athletics.” https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1653 70 Ragnarsdóttir, O, Abou-Elwafa Abdallah, M, Harrad, S (June 2024). “Dermal bioavailability of perfluoroalkyl substances using in vitro 3D human skin equivalent models.” Environment International; 188; 108772.b https://www.sciencedirect.com/science/article/pii/S0160412024003581?via=ihub 69 UpToDate (2023). “Heat Stroke in Children.” Online subscription based reference for health care providers. https://www.uptodate.com/contents/heat-stroke-in-children 68 Wertheim, J (Oct 2022). “With Hotter Temperatures Come More Football Deaths. And Black high school players are disproportionately affected.” Sports Illustrated. https://www.si.com/high-school/2022/10/07/football-climate-change-daily-cover 67 Kerr, ZY, Casas, DJ, Marshall, SW, Comstock, RD (Jan 2013). “Epidemiology of exertional heat illness among U.S. high school athletes.” J. Preventive Medicine. pubmed.ncbi.nlm.nih.gov/23253644/
66 Moritz AR, Henriques FC Jr (1947). Original source. “Studies of thermal injury II: The relative importance of time and surface temperature in the causation of cutaneous burns.” Am J Pathol.; 23:
915-941.
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● CIF Rule72 - California Interscholastic Federation Rule on air quality/particulate matter 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.”
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:73
SEC. 2. Section 38566 is added to the Health and Safety Code, to read:
73 California State Legislature (2016). “Senate Bill No. 32 = CHAPTER 249. An act to add Section 38566 to the Health and Safety Code, relating to greenhouse gas[s]es.” https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?search_phrase=4x8x16&bill_id=201520160SB 32 72 California Interscholastic Federation (Oct 2023). “CIF Sports Medicine Advisory Committee Statement on Air Quality and Sport Participation. https://www.cifstate.org/sports-medicine/aqi Item 1
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“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 both methane and ethylene74,75 and continues day and night, in ever increasing amounts for the 1,000 years it takes for it to decompose.76 Methane traps 90% more heat than carbon dioxide and is 21 times more potent. Land based plastics produce 2 times more methane and 76 times more ethylene than plastics found in waterways and oceans.
The heat islands created by plastic turf playing fields are large enough to be visible from satellites circling our planet. Even if all synthetic turf were removed from Los Angeles today, methane would linger in the atmosphere for approximately 12 years, contributing to climate change and sea level rise for hundreds of years after pollutants have been cleared from the air.77
The Lawrence Berkeley National Laboratory released a report in April 2024 finding that the greenhouse emissions from plastics is four times those emitted by the aviation industry.78 78 Karali, N, Khanna, N, Shah, N (12 Apr 2024). “Climate Impact of Primary Plastic Production.” Lawrence Berkeley National Laboratory Publications.
https://escholarship.org/uc/item/12s624vf
77 National Oceanic and Atmospheric Administration. “Methane.” https://climate.nasa.gov/vital-signs/methane/?intent=121 76 Chamas, A, Moon, H, Zheng, J (3 Feb 2020). “Degradation Rates of Plastics in the Environment.” ACS Sustainable Chemistry & Engineering;(8)9.b
https://pubs.acs.org/doi/10.1021/acssuschemeng.9b06635
75 Royer, SJ (12 Nov 2018). Letter to Mayor M Bowser, Washington DC regarding synthetic turf.
Letter to Mayor M Bowser
74 Royer, SJ, Ferrón, S, Wilson, ST, Karl, DM (2018). “Production of Methane and Ethylene from Plastic in the Environment.” PlosOne 13(8): e0200574.
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Readily reaching temperatures of 160-180F, synthetic turf creates heat islands so large they extend into surrounding areas and are visible from satellites in space, ● Methane traps 90% more heat than carbon dioxide.79
● 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.41
● GHG emissions of 527 tons of CO2e per ten-year use period per 7881m2 plastic field.80 Heat Island over Airport Park:
80 Magnusson, Simon, Mácsik, Josef (July 2017). “Analysis of Energy Use and Emissions of Greenhouse Gases, Metals and Organic Substances from Construction Materials Used for Artificial Turf.” Resources, Conservation and Recycling: (122), Pages 362-372. https://doi.org/10.1016/j.resconrec.2017.03. 79 Climate Reality Project (2020). “REPOWER AMERICA®: Methane Stinks: Why Natural Gas is Bad News For The Planet.”
https://www.climaterealityproject.org/blog/methane-stinks-why-natural-gas-bad-news-planet?_ga=2.52526 049.897177029.1647384251-251106713.1647384251
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Heat Islands over Santa Monica schools
Not Recyclable:
Less than 6% of plastics are recycled.81 Made of mixed plastics, synthetic turf is not recyclable, 81 Dell, J, Enck, J (May 2022). “The Real Truth about the US Plastic Recycling Rate.” Beyond Plastics. https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/62b2238152acae761414d698/1655 841666913/The-Real-Truth-about-the-US-Plastic-Recycling-Rate-2021-Facts-and-Figures-_5-4-22.pdf Item 1
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is a linear, not a circular product, and does not meet any definition of sustainability. The synthetic turf industry misrepresents its products when they make claims related to sustainability and environmental friendliness. It is not enough to use the vernacular of the day.
Circular products82 are “…those products that have reduced or completely no need for virgin resources and are designed with the end of their life in mind.” The United Nations defines sustainable development83 as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” The UCLA Sustainability Committee84 notes: “In simplest terms, sustainability is about our children and our grandchildren, and the world we will leave them”.
The Rutgers Center for Sustainable Materials85 definition:
“Sustainable materials are materials used throughout our consumer and industrial economy that can be produced in required volumes without depleting non-renewable resources and without disrupting the established steady-state equilibrium of the environment and key natural resource systems.”
The reality is, many landfills will not accept the massive amounts of plastic waste synthetic turf fields consist of. Removal of each regulation sized field would result in approximately 200 rolls weighing 2,000 pounds each, then transported 18 rolls per flat bed semi-truck to their disposal site. They are most often dumped on agricultural land or stored in warehouses and listed for resale to unsuspecting customers on Craigslist, Facebook Marketplace and other internet outlets. This is not recycling, but rather kicking the can down the road, leaving future generations to contend with the multiple long term human and environmental health effects from massive quantities of plastic waste.
We cannot stress strongly enough that there is NO independently verifiable “recycling” of synthetic turf anywhere. Again, claims are claims and do not constitute proof. 85 Rutgers University. “What are Sustainable Materials?” Department of Materials Science and Engineering, Center for Sustainable Materials. Accessed 26 Jan 2025. https://mse.rutgers.edu/center-sustainable-materials
84 UCLA Sustainability Committe, quoting UN World Commission on Environment and Development https://www.sustain.ucla.edu/what-is-sustainability/
83 United Nations (2024). “Sustainable Development Agenda: What is sustainable development?” https://www.un.org/sustainabledevelopment/development-agenda/#1b1981a30bdd8fde2 82 “What is a circular product?” Circular Tayside, United Kingdom. https://circulartayside.co.uk/what-is-a-circular-product-and-business-model/ Item 1
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San Martin, CA New Jersey Warehouse Pescadero, CA
Sacramento, CA Sherwood, OR
⬆️ Louisiana
Manufacturer TenCate’s “recycling” facilities
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California ⬇️
Under SB54-Allen (2022),86 “recycle” or “recycling” does not include any of the following:
● Combustion
● Incineration
● Energy generation
● Other forms of disposal
● Fuel production (except for anaerobic digestion of source separated organic materials) To be considered recycled, covered material shall be sent to a responsible end market.
Viable alternative:
As required under CEQA, Santa Monica may not choose synthetic turf when there is a feasible alternative that lessens environmental impacts, which was duly noted by theCalifornia Coastal Commission in 2023 when conditioning the baseball field at UC SantaBarbara for natural grass only.
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 ecosystem-services for the soil beneath, and provides widely dispersed rainwater infiltration allowing absorption and recharging of the water table. Additionally:87 ● 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. ● Organic management and zero emission maintenance equipment mitigate emissions, reduce costs over time, and increase carbon sequestration. 87 The Lawn Institute. “Carbon Sequestration.” Accessed 2 Feb 2025. https://www.thelawninstitute.org/environmental-benefits/carbon-sequestration/ 86 Senate Bill No. 54: CHAPTER 75: An act to amend Section 41821.5 of, to add Chapter 3 (commencing with Section 42040) to Part 3 of Division 30 of, and to repeal Section 42064 of, the Public Resources Code, relating to solid waste.
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB54 Item 1
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● Electric mowers for playing fields and chalk markers are available. ● Drought88 and desert tolerant89,90 varieties of natural grass appropriate for lawns, parks and high use playing fields are available.
● Grass fields support biodiversity, both above and below the ground.
Open green space has mental health benefits:
Natural green spaces have been shown to mitigate aggressive behavior in adolescents91 and significantly reduce the growing risk of psychiatric disorders92 and suicide mortality.93 Natural green spaces also reduce health risks such as asthma.94 The American Psychological Association95 finds:
“…exposure to nature has been linked to a host of benefits, including improved attention, lower stress, better mood, reduced risk of psychiatric disorders and even upticks in empathy and cooperation.”
95 Weir, K (1 Apr 2020). “Nurtured by nature: Psychological research is advancing our understanding of how time in nature can improve our mental health and sharpen our cognition.” American Psychological Association; Vol. 51, No. 3. https://www.apa.org/monitor/2020/04/nurtured-nature 94 Dong, Y, Liu, H, Zheng, T (13 Jan 2021). “The Impacts of Green Space Structure on Asthma in Toronto, Canada.” Med. Sci. Forum; 4(1), 6;
https://doi.org/10.3390/ECERPH-3-09123
93 Asri, A.K., Tsai, H.J., Wong, P.Y. et al (2022).
“Examining the Benefits of Greenness on Reducing Suicide Mortality Rate: A Global Ecological Study.” Frontiers in Public Health: Volume 10 | Article 902480. https://doi.org/10.3389/fpubh.2022.902480
92 Engeman, K., Pedersen, C.B., Arge, L., Svenning, J.C. et al (2019). “Residential Green Space in Childhood is Associated with Lower Risk of Psychiatric Disorders From Adolescence into Adulthood.” Proceedings of the National Academy of Sciences (PNAS.org) of the United States of America https://www.pnas.org/doi/10.1073/pnas.1807504116
91 Younan, D., Tuvblad, C., Lianfa, L. et al (2016). “Environmental Determinants of Aggression in Adolescents: Role of Urban Neighborhood Greenspace.” J Am Acad Child Adolesc Psychiatry; 55(7):591–601.
https://pubmed.ncbi.nlm.nih.gov/27343886/
90 University of Nevada, Reno. “Turfgrasses for Urban Mojave Desert Landscapes.” UNR Extension, College of Agriculture, Biotechnology & Natural Resources. https://extension.unr.edu/publication.aspx?PubID=3320
89 Baird, J (25 Nov 2024). “Drought-friendly UCR turfgrass is now on the market:The newly commercialized Coachella™ cultivar uses up to 65% less water than California's go-to choice for lawns.” University of California, Riverside; UCR News.
https://news.ucr.edu/articles/2024/11/25/drought-friendly-ucr-turfgrass-now-market 88 Los Angeles Times (9 Sep 2022). “Column: Has a UC Riverside researcher created the Holy Grail of drought-tolerant lawns?”
https://www.latimes.com/california/story/2022-09-09/uc-riverside-turfgrass-research-jim-baird Item 1
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Research96 on exposure to nature has shown associations with improved:
● Mental health
● Cognitive functioning
● Physical activity
● Sleep
● Blood pressure
● Cardiovascular health
96 Jimenez, MP, DeVille, NV, Elliott, EG et al (30 Apr 2021). “Associations between Nature Exposure and Health: A Review of the Evidence.” Int J Environ Res Public Health; 30;18(9):4790. https://pmc.ncbi.nlm.nih.gov/articles/PMC8125471/
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Hidden costs associated with synthetic turf:
● Annual GMax testing- ~$1,515. More frequently if it fails testing. A maximum result of 165 is the safety threshold advised by Sports Field Management Association, a professional association with a core mission being safety of athletes of all ages and abilities, from peewee to professional. 165 is also found in the Synthetic Turf Council STC) Glossary of Terms and Guidelines for Synthetic Turf Performance (when were Santa Monica’s plastic fields last tested for hardness?) ● Annual infill replenishment- 1.5 to 5 tons of chosen infill *plant based infill is generally 4.5 times more expensive than used tire crumb
● New maintenance equipment
● Maintenance agreement costs (required by FieldTurf warranty) ● Increased water to cool plastic surface to playable temperature. *Plastic fields readily reach 150ºF to 180ºF. No infill turf manufacturers recommend 2,000 gallons per 80k foot2 beginning 1-2 hrs. before play and repeat when temperature rises above that of natural grass (cooling effect only lasts approximately 20-50 minutes). Potable water is needed (recycled water has higher salt content, damages fibers, backing and infill). ● Cleaning solvents *failure to follow maintenance requirements can nullify warranty.
Most are approved for hard surfaces only and have negative human and environmental health affects.
● Pesticides, fungicides for weed, algae and moss eruption. Many recommended glyphosate. *weed eruption is common
● Projected removal, transportation and disposal costs *will most likely be hazardous waste landfills once under regulation and with PFOA and PFOS being declared hazardous. Santa Clara County staff reported a quote of $115k-$148k for a small field97; Fremont Union High School District is still paying off over $870k for removal and “recycling” of 6 fields in summer 2024; 6 more are planned.98 Plastic fields have needed replacement in as little as 1 to 4 yrs.
● Increased liability due to injuries, failure to disclose information regarding the toxicity to humans and the environment, and violations under the Federal Clean Water Act.
Synthetic turf is a gross misuse of taxpayer funds. It is also highly disturbing and unethical to not disclose all information to the public, particularly for a product which can negatively impact their children and the children of generations to come.
SHPFI urges you to not kick the can down the road. Should you choose to ignore the information presented here, once under regulation, you will force taxpayers to bear the costly consequences of removal, disposal and remediation of the soil prior to implementing natural grass playing fields in the future.
Its time for Santa Monica to get real!! REAL NATURAL GRASS, proper soil testing, installation and organic maintenance is the only way to protect residents and visitors to the city’s playing fields. Stop the taxpayer drain! Do what is right for current and future residents…protect our children and their grandchildren’s children from the toxic and cancer causing chemicals in and leaching from synthetic turf. Protect ground and drinking water, the bay and ocean from the toxic run-off from plastic fields. Stop the plastic waste and the microplastic pollution. Stop listening to the greenwashing by those who want to keep you returning for more of their plastic 98 Freemont Union HS District AT removal, disposal
97 Santa Clara County meeting packet 28 Jan 2025
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or otherwise benefit from incentives for installation of plastic fields every 8 to 10 years on average! Regulation is in process. So, too, will be legislation.
Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
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● Blood circulation – Children are less able to cool their body temperature by shunting their blood from their body core to their body surface due to lower cardiac output and smaller blood volume.
● Sweat production – Children produce less sweat per gland and sweat at higher body temperatures than adults.
● Fluid replenishment – Children are less likely to self-regulate hydration if unsupervised.
Children experiencing heat illness are most likely to present with significant neurological symptoms- from delirium, hallucinations, poor muscle control and unsteady gait, difficulty with speaking or unclear speech to seizures or coma. These symptoms may be readily confused with head trauma, epilepsy or drug overdose. Mortality is high and if a child survives heat stroke, their risk for recurrence of heat illness is increased.
Shade covers:
High density polyethylene (HDPE) shade sails, also known as Hypar sail72 are most often petrochemical based plastics, have a short life span (approximately 10 years, perhaps less in the coastal area). They are made from extruded plastics, and likely contain PFAS, particularly as they are often marketed as being waterproof. They are not recyclable. Even when made from green certified cloth, they, too, most often end up in landfills.73 SHPFI would recommend consideration of:
● Canopy trees
● Pavilion structures
● Pergola structures
● Solar structures
These structures provide more flexibility in design, creativity, and customization. Natural wood and unpainted steel structures decrease microplastic pollution as paint is plastic. Galvanized steel contains zinc, which leaches into soil, surface and groundwater, adds to toxic runoff, and poses a hazard to aquatic organisms.
73 Cloth shade sail https://sailshadeworld.us/recycle
72 HDPE shade sail Hypar shade sail
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Beware UV and Fire Resistant Materials:
UV stabilizers are commonly used in plastics. Outdoor products, such as synthetic turf74, pvc, rubber or other synthetic tiles and mats would be likely candidates for UV stabilizers as these plastics begin to degrade as soon as they are rolled out and exposed to UV radiation, heat, humidity, and friction from walking, running and play.75 As with PFAS and phthalates used in PVC and other plastics, these stabilizers are generally toxic and carcinogenic to humans, 72 aquatic organisms.76
Flame retardants are used widely in plastics. They are highly concerning and cause both human and environmental harm. They are toxic, endocrine disrupting chemicals and carcinogenic.77 They include such chemical classes as:
● Brominated flame retardants (BRFs)
Hexabromocyclododecane (HBCD)
Tetrabromobisphenol A (TBBPA)
● Organophosphate flame retardants (OPFRs)
● Polybrominated diphenyl ethers (PBDEs)
There are several flame retardants on the California Clean Water Act Proposition 65 List:37 ● Antimony trioxide
● Chlorinated tris [tris(1,3-dichloro-2-propyl) phosphate,TDCPP, and TDCIPP]
● Pentabromodiphenyl ether (PentaBDE) mixture [DE-71 (technical grade)] ● Tetrabromobisphenol A (TBBPA)
● Tris(2-chloroethyl) phosphate (TCEP)
Also on the Proposition 65 List, and released from PVC:
● 4-Chloroaniline
The California Department of Toxic Substances Control is currently reviewing UV stabilizers, flame retardants, colorants and more, that are used in synthetic turf. 77 International Pollution Elimination Network (IPEN), (2022). “UV-328 Communication on Recent Research.”
https://ipen.org/sites/default/files/documents/ipen-uv328-research-update-v1_2-en.pdf 76 Li, Y, Chen, L, Yang, H et al (1 Jan 2024). “Leaching of chemicals from microplastics: A review of chemical types, leaching mechanisms and influencing factors.” Science of The Total Environment; 906, 167666.
https://www.sciencedirect.com/science/article/abs/pii/S0048969723062939 75 Nzimande, MC, Mitbe, A, Tichapondwa, S et al (16 Apr 2024). “A Review of Weathering Studies in Plastics and Biocomposites—Effects on Mechanical Properties and Emissions of Volatile Organic Compounds (VOCs).” Polymers (Basel);16(8) 1103.
https://pmc.ncbi.nlm.nih.gov/articles/PMC11054226/
74 Awonaike, B, Lei, YD, Parajulee, A, Wania, F (1 Dec 2021). “Phase partitioning, transport and sources of Benzotriazole Ultraviolet Stabilizers during a runoff event.” Water Research X; (13),100115 https://www.sciencedirect.com/science/article/pii/S2589914721000281#:~:text=High%20levels%20of%20 UV328%20and%20UV234%20were,a%20sink%20than%20a%20source%20of%20BT%2DUVs Item 1
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Parents, grandparents and caretakers should not need a PhD in analytical chemistry to send children out to play. Santa Monica must act to protect both people and the environment from the toxicity of synthetic turf and motor vehicle tire products for playgrounds, pools, waterparks, landscaping and rubberized asphalt driveways…all places where people, particularly children, recreate.
Respectfully submitted,
Diana Conway, President
Dianne Woelke MSN, Board Member
Safe Healthy Playing Fields, Inc.
https://www.safehealthyplayingfields.org
SHPFI is an all-volunteer nonprofit 501-c-3
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1 David Yakobson
From: John Alle <[email protected]>
Sent: Monday, March 24, 2025 10:04 AM
To: The Santa Monica Coalition Organizer
Cc: John Alle
Subject: Restoring Funding to Our Fire Departments in LA and Santa Monica
EXTERNAL
Karen Bass of Los Angeles, and Lana Negrete of Santa Monica, are 2 mayors in LA County who signed an Emergency Declaration on Public Safety, and frequently travel outside their cities using Taxpayer funds. When will either figurehead pay more attention to public safety and refund millions taken away from their respective Fire Departments?
Insta
https://www.instagram.com/reel/DHkCi7HCTVI/?utm_source=ig_web_copy_link&igsh=MzRlODBiNWFlZA== YouTube
https://youtu.be/8rhoQwW8RSA
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2 David Yakobson
From: John Alle <[email protected]>
Sent: Saturday, March 22, 2025 6:34 PM
To: The Santa Monica Coalition Organizer
Cc: John Alle
Subject: Thank You Santa Monica Police
EXTERNAL
Thank you Santa Monica Police for saving SGI - USA Santa Monica Pacific Peace Center at 6th & Wilshire Blvd. from a reckless act of vandalism and damage this week. Soka Gakkai International is one of Santa Monica's treasured houses of prayer.
Insta
https://www.instagram.com/reel/DHheUf_Cb3N/?utm_source=ig_web_copy_link&igsh=MzRlODBiNWFlZA== YouTube
https://youtu.be/EbHw6JW1Y5k
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3 David Yakobson
From: John Alle <[email protected]>
Sent: Friday, March 21, 2025 9:14 AM
To: The Santa Monica Coalition Organizer
Cc: John Alle
Subject: FRIDAY
EXTERNAL
Where's the oversight? It's time to re-evaluate how every dollar is spent given to Santa Monica by LA County, the state of California and the Federal government for homeless services and bogus shelters. Santa Monica, barely 8.3 square miles, is BROKE, but gives away about $50 million for homeless services and provides about $10 million of grants to nonprofits whose CEO's donate to the political campaigns of Councilmembers. The MAJOR benefactors of city funds are The People Concern and its CEO John Maceri, neither of whom have been able to account for over $1.4 MILLION the last two years. Costs and results are not quantified.
Insta
https://www.instagram.com/reel/DHd4SDci9fT/?utm_source=ig_web_copy_link&igsh=MzRlODBiNWFlZA== YouTube
https://youtu.be/jH691_vMjXA
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1 Edgar Sernas
From: John Alle <[email protected]>
Sent: Wednesday, March 19, 2025 2:29 PM
To: The Santa Monica Coalition Organizer
Cc: John Alle
Subject: PARKS
EXTERNAL
'Watch your step' has taken on new meaning in the parks of LA County's 88 cities. County and City leaders say it's less expensive to watch and allow 5 -10 addicts a day to overdose and die than it is to place them in treatment centers. When was the last time Barbara Ferrer or the CEO's of Venice Family Clinic, The People Concern and Clare Matrix, to name a few, stepped into a park? The problem grows as do the monetary profits for the "homeless" industry and kickbacks.
Insta
https://www.instagram.com/reel/DHY1bxFCNSC/?utm_source=ig_web_copy_link&igsh=MzRlODBiNWFlZA== YouTube
https://youtu.be/8icwaG616zk
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1 Edgar Sernas
From: Lisa L Olson <[email protected]>
Sent: Wednesday, March 19, 2025 3:46 PM
To: Teague Weybright; Rick Valte; Shannon Parry; FRANKIE LOU THORN; Lana Negrete; Caroline Torosis; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Jesse Zwick; councilmtgitems
Subject: My garden plot and others being shaded AND MORE OF THE same old problems…..
EXTERNAL
Dear City Council members: Current garden rules are NOT being enforced on a regular basis since the beginning of the current garden management several years ago. We currently have 600- 700 people waiting for a plot on the waitlist. I feel very blessed to have my garden plot and am doing my best to utilize it. Lisa L Olson 310-625-7117
Teague,
As you know my garden plot along with several others are in the dark all winter because a protected oak tree the city stopped maintaining is shading our plots ALL WINTER.
That said, I have a short growing period of about 6-7 months. The only thing that I can grow in winter are lettuces.
The neighbors passion fruit vine is now after almost one year of growing is darkening my plot in the afternoon.
Teague, I need all the sun I can get to grow my food AND I ENJOY or USED TO ENJOY watching the sun set in my garden and now my garden has 30% or more in the dark from the shading of this unmaintained passion fruit vine. While current garden rules state “no fences” you have allowed these neighbors to plant something that is like a16’ long fence and messy! I need my summer sun and I am asking to relocate this Passion fruit vine to the center of their plot so it quits shading my plot and others.
I am tired of policing this vine and it is messy and invasive and requires constant care that neighbor gardeners are not doing. The fruit falling onto my side is attracting rodents.
The vine gets 3 feet to 5 feet wide and is planted maybe 12” to 14” from my plot. On Main Street gardens when someone relinquishes their plot IF THEIR PLOT HAD A PASSION FRUIT VINE YOU ARE RIPPING IT OUT AND REMOVING THE PLANT!
What do I need to do to get this handled?
I am told by my doctors to garden for my health but every time I go to my garden I have a mess from this vine to deal with. To say I am stressed, angry and upset is an understatement! Item 1
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2 Tell me who I can speak with or what I can do? I am a senior being bullied by neighboring gardeners who do not follow the current garden rules and for all the times I have reported them if violations were being given out in a timely manner these gardeners would have had to forfeit their plot.
You also allowed these same gardeners for maybe two years to keep this plot as they were not “actively gardening” which is supposed to require being serving timely violations every 3 weeks until comply or forfeit plot. I have dated photos and witnesses to attest to this.
What options are open to me to get this messy vine moved away from being 14” from my garden? Your assistant buddy friend—“Tom" who you found for the gardeners who were not actively gardening moved the entire nailed down border on my side to accommodate stepping stones while damaging the weed barrier I spent at least 10 hours installing. My garden is now narrower AND Tom damaged my weed cloth when he pulled up the divider AND I now have weeds many weeds coming up that were previously covered and held down by my weed barrier that was anchored down with weed fabric staples IN PLACE! TOM damaged my entire side and you gave no violation when rules state gardeners cannot go into neighboring plots without permission. He entered and damaged my plot and I have to fix it and as an almost 73 year old this doesn’t seem fair!
Sincerely,
Lisa L Olson, PDN
Photo below shows all the weeds on their side of barrier, it shows the vine growing into my plot, it shows how the vine is darkening my plot. You can see the divider that was moved to accommodate stepping stones. You can see how big and looming like a fence along the 16’ feet or so of side barrier! Item 1
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3 Above see nailed down border that was removed to put stepping stone down making my garden smaller.
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4 Sent from my iPad
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1 Edgar Sernas
From: Yuri Bukhman <[email protected]>
Sent: Tuesday, March 18, 2025 2:27 PM
To: Customer Care; Caroline Torosis; Christine Parra; Clerk Mailbox; councilmtgitems; [email protected]; Customer Service Inbox; Sparkletts; Sparkletts; Yuri Bukhman; Yuri Bukhman; Michelle Bukhman; Alex Bukhman; Fanya Bukhman; Veronika Bukhman
Subject: Sparkletts account number 944868722261265
Follow Up Flag: Follow up
Flag Status: Flagged
EXTERNAL
Attention: Customer Service & Support Top Administration!!! ******************************
•
• You had failed to Deliver the Well Promised Water delivery Again!!!!!!! 눧눨눩눪눫눦눬눭늄늅늆늇늈늁늂늃 • Also, we need you to pickup the 12 empty 5-gallon bottles from us!!!!! 눧눨눩눪눫눦눬눭늄늅늆늇늈늁늂늃 • Your quality of the service is terrible and Not Acceptable for America 🇺🇸 and our Santa Monica City Council!!! - I/We had contacted you so many times!!! - This is a sensitive health care related matter for Two Gravely Disabled Elderly People!!!!!!!!! 눧눨눩눪눫눦눬눭늄늅늆늇늈늁늂늃
• We need your support & a reasonable Services Now!!! 눧눨눩눪눫눦눬눭 •
• We expect your assistance and your response Immediately, As Soon As Possible!!!!!! 눧눨눩눪눫눦눬눭늄늅늆늇늈늁늂늃 •
Sincerely with very strong intentions,
Fanya, Alex, Yuri Bukhman and our entire Family!!!!
- The Serviced Address:
3100 Neilson Way, Unit-314
Santa Monica, CA 90405
Contact:
323.854.4440
310.392.7505
email:
[email protected]
or
[email protected]
From: Customer Service <[email protected]> Date: February 23, 2023 at 7:38:53 AM PST
To: Yuri Bukhman <[email protected]>
Subject: Sparkletts account number 944868722261265
Dear Yuri Bukhman,
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2 Thank you for contacting us via email regarding your delivery of water. We apologize for any inconvenience that you may have experienced.
We have notified your Route Sales Representative and on February 27th, 2023, he will deliver (3) three Sparkletts 5G Crystal Fresh Drinking Water. If more or less water is needed, please leave a delivery note or inform your Route Sales Representative when he arrives.
If you need further assistance please visit us at www.water.com, email us at [email protected] or contact us at 800-492-8377. Our Customer Care Agents are available Monday through Friday 8:00 a.m. – 9:00 p.m. EST As part of our ongoing efforts to provide a world-class customer experience, we’ve added a new brand to our flavored water Portfolio.
Let us interest you in a case of KARMA water for the introductory price of $25.99 -2
BILLION PROBIOTIC CULTURES
+ 100% 6 ESSENTIAL VITAMINS our ingredients are vegan and gluten-free.
Karma Probiotic Water delivers more than 10x the active cultures than yogurt. Please let us know if you are interested in adding this to your delivery Sincerely,
Diana, Customer Care Associate
Primo Water North America
Customer Care Center
Office (800) 492-8377
[email protected]
From: Yuri Bukhman <[email protected]>
Sent: Tuesday, February 21, 2023 12:12 AM
To: Customer Care <reply-fe64157677670c7d7117-822_HTML-924461185-1057339- [email protected]>
Cc: Yuri Bukhman <[email protected]>; Customer Service <[email protected]>; Customer Service <[email protected]>; Sparkletts <[email protected]> Subject: Re: Last chance to update your order!
Dear Customer Service!
…the 5-gal. bottles water delivery was not made… 솓솔솕쇔솖솗솘쇕쇖솙솚솛솜솝솞솟솠송솢솣쇗솤 Item 1
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3 • my disabled elderly mother & disabled brother were waiting for the delivery today, per your set schedule.
Please respond!
Yuri, Fanya, Alex Bukhman
323.854.4440
[email protected]
3100 Neilson Way# 314
Santa Monica, CA 90405
Sent from my iPhone
On Feb 16, 2023, at 8:04 AM, Sparkletts <[email protected]> wrote:
Need any change s? Now’s the time.
View in Browser
It’s almost time
Your order is being prepared for delivery on
Monday, Feb 20, 2023.
Please review and update your order by 3:00
pm on Sunday, Feb 19, 2023.
If you have empty bottles, remember to
leave them out for pick-up!
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4 Your delivery address
3100 NEILSON WAY 314
SANTA MONICA, CA 90405
<~WRD0000.jpg> <~WRD0000.jpg> <~WRD0000.jpg>
Now is the time to add to your order.
We are here to serve you. We offer a wide selection of products including sparkling water, both flavored and unflavored, coffee Kcup® pods, and much more. Check your delivery order and add what is needed today! Thank you for your loyalty and trust in us as your service provider. <~WRD0000.jpg>
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6 CONFIDENTIALITY NOTICE: This e-mail may contain privileged or confidential information and is for the sole use of the intended recipient(s). If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you
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CONFIDENTIALITY NOTICE: This e-mail may contain privileged or confidential information and is for the sole use of the intended recipient(s). If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you Item 1
March 25, 2025
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From: Zoe
To: LUCY F STONE; [email protected]
Cc: Christian Tago; Halima Barreto; councilmtgitems; Lana Negrete; Douglas Sloan; Josh Kurpies; [email protected]; Ramon Batista; David Gardinier; Darrick Jacob; Caroline Torosis; Jesse Zwick; Ellis Raskin; Natalya Zernitskaya; Barry Snell; Dan Hall; Clerk Mailbox; Susan Cline; Elaine Polachek Subject: Re: 25STRO01187 Notice of Ex-Parte Application & Copy of the Returned TRO Date: Thursday, March 20, 2025 11:33:03 AM
EXTERNAL
Ms. Stone,
I beg your pardon, I do not recall including you in my email. The email is not for you, the email is for Sean Besser and the Board of the Ocean Park Neighborhood Association.
As a resident of the Ocean Park Neighborhood, I am allowed to send emails to the public address of the organization that receives public funds from the City of Santa Monica. I am including the Chief of the Santa Monica Police along with its Deputy Chief, The Santa Monica City Manager and the Santa Monica City Attorney in this email so they can help you understand how transparency and ethical use of funds by neighborhood associations work.
I do remember you were one of the attendees at the May 5, 2024 Compassionate Santa Monica event hosted at Gooseegg Park last Spring. Long time since I saw you for the last time, I do not understand the hostility of your email, I have been very welcoming, hospitable, and nice to you. Perhaps you were sent to the event as an informant to see the way we managed to bring to the attention of the Santa Monica Social Justice and DEI Department our findings through the City Wide Equity Plan. It seems ironic to me that you voluntarily attended an event that supports the work of the Santa Monica Citywide Equity and a year later chose to write to me with hostility.
You should understand that in today's political climate, a Caucasian woman (you) speaking to a woman of color (me), should consider elements of cultural competence.
Training and resources are available online to express yourself with more dignity and respect. As a Board member from OPA you represent a Neighborhood, not just yourself. be kind, it does not cost you anything.
Last week, the Executive Director of The Charter for Compassion sent me an email in reference to a "group" that contacted her to ask that Santa Monica Chapter be removed from the website of the Charter for Compassion. Please note that Compassionate Santa Monica was born from a September 23, 2013 presentation that brought a unanimous vote authorizing the City Manager to sign the Charter for Compassion. No "organization" can go behind to cancel an official vote of the Santa Monica City Council.
I request that the Santa Monica City Clerk includes this email as part of next week's City Council Meeting.
Have a blessed weekend.
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On Thu, Mar 20, 2025 at 11:01 AM LUCY F STONE <[email protected]> wrote:
PLEASE...
DO NOT send me any more emails.
Thank you.
Lucy Frances Stone
On Thu, Mar 20, 2025, 10:51 AM Zoe <[email protected]> wrote:
Please take notice that on March 21, 2025 at 8:30 AM or soon after that as the matter can be heard, in Department 65 Room 302 of the Metropolitan Courthouse, located at 1945 South Hill Street, Los Angeles, CA 90007, Defendant Zoë Muntaner will and does move the Court by an Ex Parte Application for Notice of Motion and Motion to Dismiss and Terminate the (meritless) Request for Civil Harassment Restraining Orders, to the first available hearing date or in the alternative shortening time for the hearing.
Furthermore I am including a copy of the Civil Harassment Restraining Orders papers served to you by LASD Deputy Sheriff Ramirez at the Courtroom yesterday. The documents were received by you and later returned after more than 230 minutes in your possession;that is not an option after receiving, reading, evaluating and keeping court documents. The LASD have been informed.
Zoё Muntaner
“Do you have the patience to wait till your mud settles and the water is clear?"- Tao Te Ching IMPORTANT WARNING: This email (and any attachments) is only intended for the use of the person or entity to which it is addressed to and may contain privileged and confidential information. You, the recipient, are obligated to maintain it safely, securely, and confidentially. Unauthorized redisclosure or failure to maintain confidentiality may subject you to federal and state penalties. If you are not the intended recipient, please immediately notify me by return email and delete this message from your computer. --
Zoё Muntaner
“Do you have the patience to wait till your mud settles and the water is clear?"- Tao Te Ching IMPORTANT WARNING: This email (and any attachments) is only intended for the use of the person or entity to which it is addressed to and may contain privileged and confidential information. You, the recipient, are obligated to maintain it safely, securely, and confidentially. Unauthorized redisclosure or failure to maintain confidentiality may subject Item 1
March 25, 2025
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you to federal and state penalties. If you are not the intended recipient, please immediately notify me by return email and delete this message from your computer.
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1 Edgar Sernas
From: Kat <[email protected]>
Sent: Tuesday, March 18, 2025 11:04 AM
To: councilmtgitems
Subject: VOTE YES ON AGENDA ITEM 16L: EBONY BEACH CLUB
EXTERNAL
Dear Santa Monica City Council,
I write to you as a Santa Monica resident/ concerned community member,
urging you to vote YES on the Ebony Beach Club and Silas White resolution (item 16L) on March 19th, 2024. The injustice Silas White endured over 60 years ago must be repaired sooner rather than later.
It is crucial that the City Council not only bear witness to the White family cause but take action to repair the harm. Particularly in an election year, it is interesting to see how elected officials engage with the issues their constituents truly care about. Does your Black constituency matter?
In the past few years, Santa Monica has attempted to rectify the devastating harm it wrought on its Black community. However, its no secret that its attempts to repair are incongruous with the magnitude of devastation it intentionally inflicted.
In 2022, you apologized for ‘targeting communities of color for condemnation’ and vowed to ‘rectify the lingering consequences of discriminatory city policies’. What specific, measurable, and relevant actions will you take to support these words? The lingering consequences are material, so plaques and art exhibits will not suffice.
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2 I implore you to vote YES on the issue of ‘Ebony Beach Club Restitution’ to your upcoming meeting agenda, particularly Mayor Pro Tem Lana Negrete who gave a verbal agreement to back the restitution claim. Silas White’s daughter, Connie, deserves to see repair in her lifetime.
Thank you,
Kathleen Yore
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