Comment Letter Regarding Santa Clara County Fairgrounds Athletic Fields

December 13, 2023

Dear President Ellenberg and Santa Clara County Board of Supervisors, Mayor Mahan and San Jose City Councilmembers, San Jose State University President Cynthia Teniente- Matson and San Jose Earthquakes President Jared Shawlee,

I am a parent, retired software engineer, and Chair for the Sierra Club Loma Prieta Chapter Plastics Pollution Prevention committee. While applauding adding a sports complex in southeast San Jose, I would like our California San Francisco Bay Area leaders to be known for leading the nation away from plastics based athletic fields. I am also concerned about the potential of powerful sports field lighting to add significant nightly light pollution.

With new drought tolerant, tough, useable year round, hybrid bermudagrass athletic fields, East San Jose youth athletes will never experience unnecessary exposure to excess heat, increased chance of injury, illness from proprietary and unknown plastic chemical additives and eventually, as the fields wear, bodily invasive bits of plastic and microplastics.

My sons played sports growing up, including soccer, baseball and football, and my husband and I attended every game. At that time elementary through high school athletic fields were grass fields. Differences in fields taught our sons and their teammates adaptability and also appreciation for a well cared for playing surface. We were never faced with issues of excessive field surface heat, hard unresilient playing surfaces or unknown chemical exposure.

Recently our chapter, originally at the request of high school students asking for help in convincing their school and district to replace artificial turf athletic fields with grass, has focused on educating local governmental agencies, such as counties, cities, and school districts, on the need for lowering plastics usage and increasing - in California - plantings of drought tolerant landscaping and fields. There are many health and environmental reasons for foregoing hardscape carpeted plastic fields, most of which are mentioned in public Santa Clara County Medical Association letters written in support of the above mentioned students and others, https://www.sccma.org/programs/environmental-health.aspx.

As a first order approximation, I made the following ballpark calculation:
In 2015-2016 there were 3,892 high schools in California (https://high-schools.com/directory/ca/). Assuming 2 athletic fields per high school (football/soccer and baseball/softball) there would be 7784 athletic fields. As U.S. football fields are approximately 1.3 acres in size while a baseball field can be as large as 4 acres, let’s say there are 4 acres for 2 fields at every high school.
 
Then we’d have 3,892 high schools x 4 acres = 15,568 acres in California
There are 640 acres in 1 square mile, so 15,568 / 640 = 24.325 square miles of artificial turf at California high schools
 

This only covers high schools in California. There are many more elementary and middle schools, as well as fields at colleges and universities. Plus there are city and county athletic fields. But imagining 24 square miles covered in plastic is a good starting place.

Additionally we came across this much cited PLOS research article from 2018, Production of methane and ethylene from plastic in the environment, https://doi.org/10.1371/journal.pone.0200574; and more recently the main research author, Dr. Royer, contributed a newspaper commentary to the MVTimes, https://www.mvtimes.com/2019/02/20/synthetic-turf-will-contribute-greenhouse-gas-problems/

"While carbon dioxide is perhaps the most well-known contributor to climate change, methane is a far more potent gas ... Degrading plastic pollution is a source of climate change gas emissions not previously identified in the global greenhouse gas budget. If we consider globally the total surface of plastic exposed to solar radiation (in landfills, along coastlines, on playing fields, at playgrounds, in greenhouses, etc.), the problem of methane potency becomes magnified by the amount of plastic that exists worldwide. Ethylene, another greenhouse gas emitted from plastic, is produced in even greater amounts ...
 
Given that most plastic carpets are made out of polyethylene — the plastic found to release these gases at the highest rate — and given the high surface area occupied by this material, including each individual blade of plastic 'grass,' synthetic turf likely contributes significantly to greenhouse gas emissions. I strongly urge you to consider how you can reduce these gases through policies restricting the installation of synthetic turf ... to guide consumers to make better choices and reduce plastic production everywhere we can.”
 

Artificial turf wears out after 8-10 years, so every ~10 years the old plastic must be pulled up and new plastic put down. Then the old plastic must be disposed. But where? In 2020 the EPA calculated that plastics recycling, 1960 through 2018, in the United States hovered under 9%, with 75% of plastic currently buried in landfill, https://www.epa.gov/sites/default/files/2021-01/documents/2018_tables_and_figures_dec_2020_fnl_508.pdf (Tables 2, 3 & 8).

So every 10 years 75% of the above calculated 24 square miles of plastic turf (actually much more of course) winds up in landfill. As a result, if Dr. Royer is right artificial turf will also be a long term source of methane and ethylene pollution, in addition to having a well known set of health consequences, and being a known source of ocean microplastics pollution (https://www.sciencedirect.com/science/article/pii/S0269749123010965).

Regarding light pollution, Santa Clara County is in the early stages of exploring a Dark Sky Ordinance. During the October 17th Board of Supervisors Meeting, agenda item 9, the Board “directed Administration to report to the Board by the end of 2024 relating to recommended policy language applicable to the unincorporated area of the County regarding light pollution, including consideration of dark skies policies and bird safe design guidelines that are scaled appropriately to development intensity.“1 We have included a link to the IDSA sports field guidance2 and a Dark Sky Compliant field lighting product.3

Please help the state of California, Santa Clara County, the City of San Jose, and our splendid local Earthquakes Soccer team lead the nation in both community sporting venues and in building sustainable playable non polluting athletic fields that use drought tolerant bermudagrasses or other grass hybrids with Dark Sky compliant lighting that support our children and our environment.


Sincerely,

Susan Hinton
Chair, Plastic Pollution Prevention Team
Environmental Stewardship Program
Sierra Club Loma Prieta Chapter

1 https://sccgov.iqm2.com/Citizens/FileOpen.aspx?Type=12&ID=9919&Inline=True

2 https://darksky.org/app/uploads/2018/03/IDA-Criteria-for-Community-Friendly-Outdoor-Sports-Lighting.pdf

3 https://darksky.org/what-we-do/darksky-approved/products-companies/#!/Sports-Lighting/c/155896458