bethelhem.telahun@sanjoseca.gov
Dear Environmental Project Manager Telahun,
Regarding the Columbus Park Redevelopment Project, File Nos: ER20-02
The Sierra Club Loma Prieta Chapter welcomes this opportunity to provide comments on the recirculating Initial Study and Mitigated Negative Declaration (IS/MND) for the Columbus Park Redevelopment Project. The Sierra Club Loma Prieta Chapter strongly opposes installing synthetic turf.
The project is planned on approximately 12.5 acres and includes construction of new lighted multi-sport playing fields and courts. The proposed playing fields would include synthetic turf and would be designed for use as softball or soccer fields. The IS/MND was originally circulated for public review from February 8, 2023 to March 2, 2023, and is currently recirculating until August 5, 2024.
On May 4, 2023 the document “Responses to Public Comments” was published by the CEQA Lead Agency (the City of San Jose Department of Planning, Building and Code Enforcement in consultation with David J. Powers & Associates). It includes responses to earlier questions concerning synthetic turf. Immediately below are observations, objections and questions regarding a few of the CEQA Lead Agency responses.
Synthetic turf is not solely made up of “natural infill” which is but one component of a multi-layered hardscape and semi-impervious sports field system [1].
In addition to infill, which consists of loose granules meant to sit between carpet blades, the top “carpet” layer of synthetic turf (ST) typically consists of one or more of the following molded and stretched plastic threads: LLDPE (linear low density polyethylene), polypropylene, and nylon [1][2]. The carpeting blade “tufts" are held in place by one or more backing layers, which may consist of an acrylic coating, polyurethane, latex or “other suitable coatings for fabrics[1].” Besides the carpeting layer and separate backing material, other layers may include a mixed plastics shock absorbing pad, a geotextile fabric layer (85% synthetic polymers containing stabilizers or inhibitors to resist UV light [3]), a drainage layer, and an irrigation system [1].
Each of the plastic layers includes stabilizers and conditioners, and may include colorants. Some of the known additives include PFAS[9] and lead[1]. Lead and particular PFAS chemicals are considered hazardous by the State of California [19]. The City’s CEQA Lead Agency Response C.3 is not adequate because the Agency did not account for the carpet layer or other layers of a synthetic turf sports field system.
All plastics are subject to wear, especially the ST carpet layer which is exposed to sunlight, air, weather elements including rain, wind, etc., foot traffic, dust, and miscellaneous items carried onto the field. It is well documented that carpet tuft plastic blades become thin and break into pieces, and that this wear is the reason for 8-year sports turf warranties [4]. Blades and pieces, including microplastics and nanoplastics, wash or are blown into storm drains, which carry the plastic into watersheds and ultimately into the ocean [5].
There is no single highly effective way to filter microplastics and nanoplastics from storm drains or at drinking water treatment plants using mechanical filtering, and costs increase with more effective mechanical methods [6]. Bioretention areas (a.k.a. rain gardens) for example, are proposed to address these tiny particles, with research showing that they are able to filter as much as 85% of microplastics but not nanoplastics [7], so both still flow through the system. Another study of 13 bioretention filters growing highly specific plants was shown to remove nanoparticles but unfortunately, for polyethylene and polypropylene, components of ST carpets, only 83% of them were removed [8]. An incredible number of microplastics and nanoparticles are shed by ST, and 15% - 17% of an incredible volume is still an incredible amount. As bad as that is, bioretention cells themselves degrade, the plants and soil eventually become overburdened, and there is not a way to effectively remove microplastics from the bioretention cells [7][8].
Bioretention cells are clearly not a solution to ST microplastics problems. Furthermore, when there is no rain, as can be true for months at a time in San Jose, or irrigation, microplastics and nanoplastics are borne aloft by wind. This type of vector carries the microplastics and nanoplastics above and beyond any bioretention cells. The most common microplastics found in the atmosphere, even above Mt. Fuji in Japan, include polyethylene, polypropylene and polyurethane, which are three plastics found in ST [10].
The IS/MND needs to look again at greenhouse gas emissions with ST in mind.
While there are many research studies concerning artificial turf and greenhouse gasses reaching varying conclusions, it’s incontrovertible that plastic production is a key contributor to climate change and that polyethylene, polypropylene and polyurethane found in ST carpet and shock pad layers, along with other specific plastics, release significant amounts of greenhouse gas throughout their lifecycle [11]. “Lawrence Berkeley National Lab, estimates that by 2050 plastic production could account for 21% to 31% of the global carbon emission budget required to limit global temperature increase to just 1.5 degrees Celsius [11].” The World Meteorological Organization states that we have likely already breached, if only temporarily, the 1.5°C threshold [12], making efforts to further contain temperature rise all the more urgent.
Another highly cited article from 2018 found that when polyethylene, including virgin low-density polyethylene used in ST, reaches seawater and is exposed to sunlight, it releases methane and ethylene, which itself causes increases in ozone, carbon monoxide and other pollutants [13]. As stated previously, bioretention cells allow at least 15 - 17% of detached microplastics and nanoplastics to enter our watershed [7][8].
Properly installed and managed grass, on the other hand, has been repeatedly shown to sequester CO2 even “after accounting for mowing, fertilizer, and N2O emissions.” The sole exception to improved land-use CO2 sequestration upon installing and properly maintaining grass over 50 or more years comes from grass installed in previously forested areas [15].
ST warranties are for 8 years since ST deteriorates and must be replaced every 8 - 10 years [4], and an average 80,000 sq. foot athletic field carpet layer contains 40,000 lb.s of plastic [2] There is not a way to sustainably recycle the mixed plastic with the various stabilizers, colorants and conditioners that are part of ST [17][18][1][9]. ST is therefore either cut and resold through venues such as Facebook Marketplace (search “Facebook marketplace synthetic turf”) or landfilled every 8 - 10 years, meaning that eventually pieces of plastic, complete with their added chemicals, will degrade and enter the watershed or atmosphere [16][7][8][10]. ST is a long way from a zero waste candidate.
Regarding an anticipated reduction in water demand due to ST, there are a few considerations not taken into account by the IS/MND.
ST does in fact use water, especially as temperatures rise. That ST heats up to 60°F - 80°F hotter than the ambient air temperature is so well known as a potential source of heat stress in humans, that the Netherlands Water Research Institute developed an experimental rain water capture and evaporative mechanism in an attempt to mimic the natural ability of grass to transpire [21].
Also, while natural grass can make use of reclaimed water (purple pipe) water, ST must use potable (drinking) water. A California Coastal Commission memo, denying UC Santa Barbara’s request to replace a grass baseball field with a synthetic turf field, specifically discusses use of reclaimed (recycled) water while conserving potable (drinking) water, stating "The proposed impending development involves the installation of three acres of impermeable plastic-based artificial turf field where a permeable natural turf field had existed before, and would require a switch from reclaimed water use at the existing field to potable water use at the proposed field. ... The project ... does not provide necessary analyses in relation to impact minimization for potential increases to runoff volume, flow rate, timing, and duration that could be caused by the increase in impervious surface area that the field would entail ... Although water demand at the proposed artificial field was analyzed and confirmed to offer a significant reduction over the current field’s water demand, the proposed field would utilize potable water instead of currently-used reclaimed water, due to the higher salt and mineral content present in reclaimed water [20].”
Note that the Coastal Commission calls ST “impermeable.” While it’s true that ST can be made somewhat permeable by poking holes through the carpet’s backing layer and through the shock pad (if used), pores in ST can be overwhelmed by a heavy rain or even by purposeful irrigation, resulting in puddling on the field [22],or they may become plugged by the continually shedding ST.
Sustainably managed, drought tolerant natural grass seed mixes and hybrids are the only environmentally sensible outdoor multipurpose athletic field ground covers. The Sierra Club Loma Prieta Chapter Plastic Pollution Prevention Team has information on drought tolerant grasses developed for the Western United States and on sustainable athletic field management practices which we would be glad to share.
Sustainably yours,
Susan Hinton, Lead
Plastic Pollution Prevention Team
Sierra Club Loma Prieta Chapter
References
1. 2023 July, The Synthetic Turf Council. Guidelines for the Essential Elements of Synthetic Turf Systems.
https://cdn.ymaws.com/www.syntheticturfcouncil.org/resource/resmgr/guidelines/advertising/2023_Guidelines_for_the_Esse.pdf
2. 2017 October, The Synthetic Turf Council. A Guideline to Recycle, Reuse, Repurpose and Remove Synthetic Turf Systems
https://www.ttiionline.com/wp-content/uploads/2015/01/STC-Guideline-for-Recycle-Reuse_2017.pdf
3. 2009 January, National Standard Material Specifications. Chapter 3, Part 642 National Engineering Handbook, Material Specification 592-Geotextile
https://web.archive.org/web/20221018232843/https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_016396.pdf
4. Various dates. Warranty examples and FAQs.
https://sporturf.com/wp-content/uploads/2014/05/8-Year-Manufacturers-Limited-Warranty-with-Signatures-GrassTex.pdf
https://alwaysgreensyntheticgrass.com/sports-turf-warranty/
https://fieldturf.com/en/why-fieldturf/faq/
5. 2023 October, The University of Barcelona. The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments
https://www.sciencedirect.com/science/article/pii/S0269749123010965
6. 2021 October, Chemical Engineering Journal. Identification and removal of micro- and nano-plastics: Efficient and cost-effective methods
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8422880/
2021 November, Chemosphere. Understanding the fragmentation of microplastics into nano-plastics and removal of nano/microplastics from wastewater using membrane, air flotation and nano-ferrofluid processes
https://www.sciencedirect.com/science/article/abs/pii/S0045653521015253
7. 2024 July, Journal of Environmental Sciences. Microplastics removal from stormwater runoff by bioretention cells: A review
https://www.sciencedirect.com/science/article/abs/pii/S100107422400370X
8. 2024 April, Journal of Hazardous Materials. Removal and Release of Microplastics and Other Environmental Pollutants during the Start-up of Bioretention Filters Treating Stormwater
https://www.sciencedirect.com/science/article/abs/pii/S100107422400370X?via%3Dihub
9. 2024 March, Public Employees for Environmental Responsibility. PFAS in Artificial Turf Coats Players’ Skin
2024 March, Center for Environmental Health. New Testing Reveals High Levels of Toxic PFAS in Artificial Turf
https://ceh.org/latest/press-releases/new-testing-reveals-high-levels-of-toxic-pfas-in-artificial-turf/
2023, The State of New Jersey Department of Environmental Health. PFAS in Artificial Turf Technical Memorandum
https://dep.nj.gov/wp-content/uploads/dsr/pfas-artificial-turf-memo-2023.pdf
10. 2023 May, University of Queensland, Imperial College London, University of Exeter. There's something in the air: A review of sources prevalence and behaviour of microplastics in the atmosphere
https://www.sciencedirect.com/science/article/pii/S0048969723008094
2023 August, Waseda University in Japan, Airborne hydrophilic microplastics in cloud water at high altitudes and their role in cloud formation
https://link.springer.com/article/10.1007/s10311-023-01626-x
2023 February, YaleEnvironment360. Microplastics are Filling the Skies. Will They Affect the Climate?
https://e360.yale.edu/features/plastic-waste-atmosphere-climate-weather
11. 2024 April, National Resource Defense Council (NRDC), Hidden Fossil Fuels: Plastic Production Drives Climate Change
https://www.nrdc.org/bio/renee-sharp/hidden-fossil-fuels-plastic-production-drives-climate-change
2024 April, Lawrence Berkeley National Lab, Climate Impact of Primary Plastic Production
https://energyanalysis.lbl.gov/publications/climate-impact-primary-plastic
12. 2024 June, World Meteorological Organization. Global temperature is likely to exceed 1.5°C above pre-industrial level temporarily in next 5 years
https://wmo.int/media/news/global-temperature-likely-exceed-15degc-above-pre-industrial-level-temporarily-next-5-years
13. 2018 August, University of Hawaii. Production of methane and ethylene from plastic in the environment
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0200574
14. 2019 December, The Atlantic. The Dangerous Pileup of Artificial Turf
https://www.theatlantic.com/science/archive/2019/12/artificial-turf-fields-are-piling-no-recycling-fix/603874/
15. 2023 February, USDA Agricultural Research Service & Universities in Oregon, Delaware, Texas. High soil carbon sequestration rates persist several decades in turfgrass systems: A meta-analysis
https://www.sciencedirect.com/science/article/pii/S0048969722070747
16. 2024 July, The Boston Globe. Tons of abandoned artificial turf raises questions about recycling promises
https://archive.ph/2024.07.18-190252/https://www.bostonglobe.com/2024/07/18/science/artificial-turf-not-being-recycled/
17. 2023 October, Beyond Plastics (Bennington College) and IPEN (International Pollutants Elimination Network). Chemical Recycling A Dangerous Deception
https://static1.squarespace.com/static/5eda91260bbb7e7a4bf528d8/t/655791f76ad9bb07d10e1290/1700237880522/10-30-23_Chemical-Recycling-Report_web.pdf
18. 2024 July, The Guardian. Shell quietly backs away from pledge to increase ‘advanced recycling’ of plastics
https://amp.theguardian.com/business/article/2024/jul/17/shell-recycling-plastic-pledge
19. 2023 December, The California Office of Environmental Health Hazard Assessment (OEHHA). The Proposition 65 List
https://oehha.ca.gov/proposition-65/proposition-65-list
20. 2023 November, California Coastal Commission. Memo W13.1a, Subject: Notice of Impending Development UCS-NOID-0002-23 (Baseball Stadium Turf) for Public Hearing and Commission Action at the December 13, 2022 [sic], Commission Meeting
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf
21. 2024 July, Water Research Institute / Netherlands. Climate adaptive solution for artificial turf in cities: integrated rainwater storage and evaporative cooling
https://www.frontiersin.org/journals/sustainable-cities/articles/10.3389/frsc.2024.1399858/full
22. 2017 April, FieldTurf. Maintenance Guidelines
https://fieldturf.com/workspace/uploads/files/fieldturf_brochure_maintenance-guidelines_apr2017_006.pdf
Begin forwarded message:
---------- Forwarded message ---------
From: Telahun, Bethelhem <Bethelhem.Telahun@sanjoseca.gov>
Date: Tue, Jul 16, 2024 at 12:09 PM
Subject: Public Notice of Intent to Adopt a Negative Declaration for the Columbus Park
Redevelopment Project (ER20-025)
To:
PUBLIC NOTICE
INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION
CITY OF SAN JOSE, CALIFORNIA
Project Name: Columbus Park Project
File No.: ER20-025
Description: Public project to demolish all existing park facilities and recreational equipment on-site and construct two new soccer fields, lawn practice areas, a kids’ soccer area, a play area, four pickleball courts, one futsal/pickleball/basketball court, and two new horseshoe pitches. The redeveloped park would also include a picnic area, restrooms, a pedestrian paseo, two gravel surface parking lots, a 525-square-foot maintenance building and a storage shed. The project would also vacate Spring Street between West Taylor Street and Ashbury Street, reconfigure Irene, Asbury, and Walnut Streets to a one-way loop road around the site. The project would remove all 105 existing trees and plant 133 new 24-inch box trees.
Location: The project site is the existing Columbus Park site, bound by Asbury Street to the north, West Taylor Street to the south, Irene Street to the east, and Walnut Street to the west, in the City of San José.
Assessor’s Parcel No.: 259-07-115 and 259-08-103 Council District: 6
Applicant Contact Information: City of San José, Department of Public Works (Attn: Chris Mastrodicasa); 200 East Santa Clara St, 6th floor, San José, CA 95113; (408)775-5700; chris.mastrodiscasa@sanjoseca.gov
The City has performed an environmental review of the project. The environmental review examines the nature and extent of any adverse effects on the environment that could occur if the project is approved and implemented. Based on the review, the City has prepared a Draft Mitigated Negative Declaration (MND) for this project. An MND is a statement by the City that the project will not have a significant effect on the environment because the project will include mitigation measures that will reduce identified project impacts to a less than significant level. The project site is present on the list pursuant to Section 65962.5 of the California Government Code.
The public is welcome to review and comment on the Draft MND. The public comment period for this Draft MND begins on Tuesday July 16, 2024 and ends on Monday August 5, 2024. The Draft MND, Initial Study, and reference documents are available online at: www.sanjoseca.gov/negativedeclarations
The documents are also available for review with an appointment during normal business hours at the City of San Jose Department of Planning, Building and Code Enforcement, located at City Hall, 200 East Santa Clara Street; or during normal business hours at Dr. Martin Luther King, Jr. Main Library, located at 150 E. San Fernando Street; and the Joyce Ellington Branch Library located at 491 East Empire Street. Please contact Bethelhem Telahun at (408) 535-5624, or by e-mail at bethelhem.telahun@sanjoseca.gov for appointment request or additional questions, comments, or concerns.