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HomeMy WebLinkAboutSS3 - CIP Early Look - CorrespondenceReceived After Agenda Printed March 8, 2022 Item No. SS3 From: D Woelke To: DDe t - City Council; City Clerk"s Office Subject: Public Comment on Plastic Grass - SS3. Capital Improvement Program (CIP) Early Look. Date: March 07, 2022 2:13:45 PM Attachments: OPEN LETTER TO STAKEHOLDERS.odf [EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe. Mayor, Council Members and all, I am respectfully submitting comments for the public record and ask that you carefully consider properly installed and maintained natural grass playing fields rather that adding to the human and environmental health burdens associated with replacement of the massive plastic grass playing fields you propose replacing. There are organizations that provide cost effective pilot projects to assist with training. You also have Irvine as a stellar example of how this can be done. As you are well aware, Orange County is already battling significant PFAS contamination to it's water supply (1 2 3). California is moving to regulate PFAS at the parts per quadrillion level opening anyone who rolls out PFAS containing synthetic turf to law suits. There is turf no PFAS free synthetic . There is no recycling. Anyone who claims otherwise is subject to reporting to the CA State Attorney General and the Federal Trade Commission under "greenwashing" provisions. Lastly, I would like to ask that you openly and directly engage ALL stakeholders, including those who elected you to office, beginning with openly posting all controversial subjects, such as petrochemical plastics, including synthetic turf. Please do not hesitate to request additional information. Respectfully, Dianne Woelke MSN, Board Member Safe Healthy Playing Fields Inc. www.safehealthy_playingfields.org Why Your Community Should Reject Plastic Synthetic Turf Fields SHPFI -- February 2022 Who are we? Safe Healthy Playing Fields Inc. is an all -volunteer non-profit 501-c-3. We are committed to educating communities and policy -makers about the realities of plastic fields versus grass fields for their parks, schools, etc. SHPFI urges you and your community to have an informed conversation with all stakeholders on this issue. We hope the points made below are helpful and we would be glad to provide more information. Why plastic synthetic fields are not a solution: There are five categories of reasons for rejecting plastic, synthetic fields in your community: cost, toxicity, heat, injury and disposal. Below is a very brief look at each of those five points. SHPFI can help you find the voluminous research on these and many other aspects of this issue. Cost: Many communities are looking at plastic fields as a money -saver. The reality is that with a cost of up to 4.3 times more than natural grass over the 8 years of a typical warranty, it's a very poor financial investment for those looking beyond the ribbon -cutting. Maintenance and replacement costs are often minimized. Disposal costs are frequently omitted altogether, and concerns about liability for many of the issues below is an unsettled area of law. Toxicity: Plastic turf fields are a petrochemically derived product with an enormous carbon footprint, extending from fossil fuel extraction and processing to the carpet's manufacturing and transport, to its finite use as a field, to its unregulated and highly uncertain disposal. The toxicity of plastic fields is not in doubt, regardless of brand or "recipe." The components in any synthetic turf include highly variable and undisclosed combinations of toxins like: per- and polyfluoroalkyl substances (PFAS), heavy metals, carcinogens, endocrine disruptors, phthalates, volatile and semi -volatile organic compounds, as well as the leachate from the plastic carpet `blades' and the backing, plus the full -field shockpad, infill blend, and the hundreds of gallons of glue needed for installation and ongoing repair. The synthetic turf industry concedes it uses PFAS in manufacturing. This is significant because PFAS, a class of over 12,000 chemicals dubbed "forever chemicals," persist in the environment. and bioaccumulate in everything: humans, wildlife, soil, water and aquatic organisms. They threaten biodiversity, our food chain and our health. They never leave. Heat: Plastic fields can also get unbearably -even lethally- hot. Regardless of infill type these fields are reliably hotter than adjoining asphalt. Even Brock USA admits their pine -based infill only reduces surface temperature by 20F. Some plastic fields have clocked in as high as 200oF in the west and mid -west. Excessive heat is a particular risk for young children. In contrast, grass fields typically remain a few degrees above or below ambient temperatures. Heat can lead to burns – separate from the notorious, limb -shaving turf burns created by friction. Thermal burns on plastic turf have even required hospitalization. At a surface temperature of 118°F a first-degree burn occurs in 15 minutes, becoming a 3rd degree burn (full skin -thickness) at in 20 minutes. Even a young child would be able to call for help in that time. But at a surface temperature of 140°F. 1st degree burns occur in 3 seconds. and 3rd degree burns in 5 seconds. Some claim plastic turf fields can be cooled with occasional water -spraying. While proper irrigation or water -cannon system can lower the temperatures for 20+ minutes, plastic fields rapidly return to the high temperatures. According to recent research: "... 480, 000 L of water at 25°C are required to decrease the surface temperature from 60°C [140°F] to 30°C [86°F] ... the amount of water required to maintain (artificial turf] temperatures at levels comparable to irrigated (natural turf] over a 24-h period exceed the water requirements of Bermuda grass in the same environment." Also, an irrigation system can run into hundreds of thousands of dollars— a cost that should be part of any realistic comparison. Irrigating a plastic field before play doesn't keep it cool enough to last through a soccer game. Rather, it requires interruption of play for 20+ minutes while also changing conditions of play, becoming more slippery, causing some infills float or have clumping problems. With the increased humidity comes increased risk of exertional heat stroke. Not only will synthetic turf not conserve water, it will pack the earth and bake it, kill all living organisms below it and increase runoff. While runoff from any kind of field must be managed, the extra challenge with plastic fields is its super -heated runoff with an unquantified toxic load of mixed, undisclosed chemicals, including PFAS and heavy metals. None of these issues are addressed in field plans, which typically focus on maximizing the field's performance- not on the impacts on water quality or stormwater management. Also, the Best Management Practices (BMPs) cannot begin capture all of the microplastic infill and blades, and will capture virtually none of the chemical leachate. These materials have widely varying sizes, buoyancies and densities, making their capture unrealistic, overly expensive, or both. Adding to the list, plastic grass carpet generate massive heat islands larger than their actual size. A regulation sized field is about 80k square feet, or 2 acres, comprising approximately 800,000,000 plastic blades per field. Both the field surface and the surface of each blade reflect heat, triggering visible waves of heat rising and spilling into adjoining areas like schools or spectator stands. The entire surface area of heated plastic constantly off -gasses both methane and ethylene. These greenhouse -gases are highly toxic chemicals that everyone on and near the field -children, athletes and bystanders- will constantly inhale. They are released in increasing volume as the blades break down from UV light, weather, age and grinding action during play. The off gassing continues even at night and will continue for the hundreds of years it takes for these materials to decompose. Choosing to install plastic synthetic turf is choosing to promote climate change. In contrast, living natural grass provides multiple un -monetized functions: 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 fields naturally filter toxins, perform important eco -services for the soil beneath, and provide widely dispersed rainwater infiltration allowing absorption and recharging of the water table. Natural grass fields can even be maintained pesticide free, and have been in existence for many years. Most `failing' natural turf fields were inexpensively installed, for example without soil amendment or engineered drainage. They typically receive inadequate aeration, over -seeding etc., use an off-the-shelf seed mix that doesn't optimize performance for climate, soil and use, and are not supported by trained professionals. These steps will produce a robust, high -traffic grass field that is safer, softer and cooler than plastic turf. Disposal: There should be no confusion: There is NO recycling anywhere in the US. Repurposing is not recycling. Incineration is not recycling. Even the industry acknowledges this. The only approximation is in Europe at two plants that appear to be shredding, separating and downcycling the small number of fields they can handle. The owner of one plant has declared he will not accept fields from more than a few hundred kilometers away. The plastic waste problem posed by these fields has multiple aspects, both during its "useful" life and after removal. The industry itself estimates that each field loses one to five tons of infill, per year. Where is it going? Additionally, increasing amounts of blades come loose or break off. The International Association for Sports and Leisure Facilities states (27 Aug 2019) the "mechanical wear from high tread loads — as arising during football or rugby — causes tiny particles or blades of artificial grass to break off. This amounts to 250 to 300 kg per year for modern sports pitches." That is 551-661 pounds of PFAS laden microplastics readily lofted into the air by field activity or weather- per field, per year. Together with the 1,000-10,000 pounds of migrating infill, they are lost to soil, water tables, waterways and storm drains. Drainage systems on a plastic fields are geared to maximizing the field's performance, not protecting water quality from contaminated runoff. There is concern that stormwater runoff from fields may violate the Federal Clean Water Act, potentially triggering fines of $10,000 per day. Choosing to install synthetic turf is choosing to increase legal liability and the plastic waste burden to your community and the planet. As the synthetic turf industry has worked to address these issues, many have turned to alternative infills including "bio" or plant -based infill (PBI). The materials are often sourced outside the US from countries that have abysmal pesticide and toxicity regulations. Additionally, plant -based indicates there are other materials, typically silica sand —not beach sand but silica sand, a cancer causing chemical on the CA Proposition 65 list list since 1988. Further, just because something is plant -based does not make it safe to roll in or breathe the dust from. Nor does it mean the materials are pesticide, chemical or PFAS-free. For example, Brockfill, sourced from US grown knotty yellow pine, has tested very high for Total Organic Fluorine, an indicator for PFAS. Similarly, just because an infill is plant -based does not mean it is sustainable. The harvested components are often sent across the globe for processing, then shipped back and transported across the country for sale. This is unsustainable. Many plastic turf companies make claims of carbon neutrality without verifiable evidence. For example, Brock USA claims its PBI captures carbon dioxide-- without disclosing the carbon dioxide released by harvesting 7-9 year-old trees, or the GHG emissions from transporting, processing and delivering the product. The cost to landfill a regulation sized field (80k square feet) is variable, but we approximate it at $65,000. That's 400,000 pounds of infill and 40,000 pounds of plastic carpet. Most US fields are 120k square feet, or larger. These plastic carpets are made by companies that manufacture household carpets. As with PFAS-containing household carpets, synthetic turf is rapidly headed toward regulation in California (pg 14) and other states. The cost to dispose of a used synthetic turf field may increase dramatically if regulated as hazardous waste. These plastic fields impose numerous other uncalculated costs, such as hidden maintenance and safety testing requirements that most non-professional venues don't even know about -much less perform. The cost of perpetually replacing one to five tons of lost infill -per field, per year, on top of replacing 40,000 tons of mixed plastic carpet each 8 or so years, will also increase. Choosing synthetic turf is choosing to increase taxpayers' burden. Injury: Near the top of parents' list of concerns is the matter of injury rates. Athlete concussions are of particular concern. Plastic fields are notorious for getting dangerously hard, even among elite athletes on premium fields. The Concussion Legacy Foundation estimates that between 315,000 and 850,000 concussions occur among US high school athletes each year from impact with a playing surface, not another player. Five- to 12 -year-olds are especially vulnerable to concussion, both developmentally and biomechanically. They are more likely to sustain a concussion, due to head -to -body mass ratio and less developed neck musculature, making them less able advert a head -to -surface impact in a fall. At age six, a child's head is 90% of adult size while their body is about 20%. Newer synthetic fields (3rd and 4th generation) require a greater fall distance in order to attenuate head to surface impact. This puts children at a higher risk for concussion when playing on synthetic turf. Natural grass is shown to attenuate head -to -surface impacts better. Field hardness also affects joints with repeated impacts. Joint injuries, especially to lower extremities with twisting and cutting as athletes change direction at speed, are higher on synthetic grass fields. Independent, peer reviewed research --the gold standard for scientific evidence-- clearly shows a dramatic increase in non -contact injuries on synthetic turf over natural grass. Multiple studies by the NFL and NCAA have confirmed the dramatic increase in lower -extremity injuries on plastic fields. Be alert to special-interest or industry -funded research which does not meet this rigorous standard of scientific integrity. These `studies' even go so far as cherry -picking data from the published research to reach their preferred, inaccurate conclusion. This distorts credible, proven evidence, in service of a global, multi -billion -dollar industry. The reality is beyond dispute: Even at the NFL where money is no object, choosing synthetic turf is guaranteeing more injuries. What are the chances a school or park can solve what even the NFL cannot? Finally, children are not short adults when it comes to toxicity: they are always impacted to a higher degree than adults when exposed to chemicals, due to their size and developmental windows. Low dose exposure, especially to mixed chemicals, can lead to cancers that may take years to develop. Patents reveal manufacturers use a variety of PFAS and dozens of other chemical of concern. Ninety percent of cancers are environmentally linked. Childhood cancers have increased 57% since 1975. Choosing synthetic turf may add to that risk. Proceed thoughtfully SHPFI urges you to weigh your decision carefully. The impact of this choice on human and environmental health should be of paramount interest. How does an ongoing cycle of adding this volume of toxic plastic to your environment, landfill and budget help you meet the goals of your municipality's Climate Action Plan? Zero Waste Plan? Newly passed recycling laws? Choosing synthetic turf is promoting more investment in the fossil fuel and plastic industries. What message do you hope to impart to students about environmental stewardship? Once you choose plastic turf, the cost of returning to natural grass can be prohibitively expensive. With plastic pollution expected to double by 2030. Our children and their grandchildren's grandchildren, will inherit the consequences of decisions made today. Protect their health, the environment and their future. Please let common sense rule. Say NO to plastic grass, and support carbon -sequestering, cooling and naturally cleansing natural grass playing fields. We would be glad to address any questions you may have. Respectfully, Diana Conway, President Dianne Woelke MSN, Board Member Safe Healthy Playing Fields, Inc. www.safehealthyplayingfields.org SHPFI is an all -volunteer nonprofit 501-c-3 Consider supporting our work with a tax-deductible contribution! EIN: 83-424-3172