June 17, 2024
Jed Mettee, COO
San Jose Earthquakes
1123 Coleman Ave
San Jose, CA 95110
Dear Mr. Mettee,
I would like to thank you and Kevin Moore from Colony Landscaping for taking the time to meet with members of the Sierra Club, Safe Healthy Playing Fields, Mothers Out Front, and the Community for Natural Play Surfaces. As a result we all have a better understanding of everyone’s views and concerns.
About references
Toward the end of our meeting you mentioned welcoming references and criteria for selected references. In scientific, medical, and academic circles, the most valued papers, letters, and opinions are from recognized established researchers or authors independent of commercial concerns, especially ones who are not paid directly or indirectly, e.g. through grants, by commercial concerns. In addition, research papers are more highly valued when the research is published in a peer-reviewed journal known to carefully vet scientific, medical, or academic findings through a transparent review and editing process.
In the Sierra Club, when our teams or committees cite scientific, medical, or academic documents, we have our own review process to ensure relevant and sound material.
When enough good scientific, medical, or academic references agree, almost everyone (there are always outliers) accepts the findings as being firmly established. For example today all experts accept that the earth is going through a period of warming and climate change.
About plastic
There is enough consensus on a plastics pollution crisis that the United Nations is working on a global plastics treaty [1]. Furthermore, the greenhouse gas released as a result of plastics lifecycle is notable and alarming. The complete plastics lifecycle includes petroleum extraction specifically for plastics, then plastics production, plastics commodity manufacturing, plastics usage, and plastics disposal [2][3]. The executive summary for Lawrence Berkeley National Laboratory’s report Climate Impact of Primary Plastic Production [2] states “The rapidly increasing production of plastics and the continued reliance on fossil fuels for feedstocks (i.e., raw materials) and process energy (i.e., energy required for process heat and electricity), have contributed to numerous environmental problems and health harms. As a result, plastic pollution has become an increasing threat to natural ecosystems, human health and climate.”
There is much more in the report but for us it may be enough to note that, in addition to “an increasing threat to natural ecosystems, human health and climate,” there are two key graphs. One, on Executive Summary page 2, shows that in 2019 the production of plastics that are used for artificial turf (and other products), low density polyethylene (LDPE), linear low density polyethylene (LLDPE) and polypropylene (PP), totaled 29% of global plastic production. The other graph, on Executive Summary page 4, shows that in 2019 the subsequent release of GHG (greenhouse gas) as a result of production for those three plastic polymers totaled 26% of global plastic production related GHG.
About artificial turf and global impact
If it’s tempting to think that the manufacture or use of artificial turf must be a limited product and that many other things must also be made from LDPE, LLDPE and PP, consider that in 2023, when University of Barcelona researchers sampled plastic pollution in the ocean off the coast of Barcelona, fully half of their plastic samples contained artificial turf and that more than 15% of all plastic collected was artificial turf [4]. The samples they collected came from the surface waters to the ocean floor and artificial turf fragments ranged in size from nearly complete blades down to micro and nano plastics (less than 5 mm).
Furthermore, when mixed plastics combine in sunlight with sea water, researchers at Northeastern University found that “Three plastics — polyethylene, polypropylene and expanded polystyrene — are particularly common marine sights; together making up roughly 70% of the plastics produced in the world ... Stubbins found 319 to 705 chemical products were formed from the plastics exposed to light. The expanded polystyrene broke down and produced ‘a higher diversity of chemicals’ than the polyethylene and polypropylene. ‘Once you photodegrade them — especially, polystyrene — the chemicals can recombine and produce hundreds of different chemicals,’ Stubbins says ... Meanwhile, the polypropylene and polyethylene produced dissolved fatty acids ‘resembling the parent material,’ Stubbins says. But these chemicals can be used as food by microorganisms in the ocean. [5]” Again, polyethylene and polypropylene are the main plastics in artificial turf.
As we’ve seen, microplastics, including artificial turf, migrate into our watersheds and air [6], and into our bodies [7][20][21]. “Microplastics have been detected throughout the human body, including in the blood, saliva, liver, kidneys, and placenta.” Additionally, medical models show these can cause “inflammation, cell death, lung and liver effects, changes in the gut microbiome” and more.
About artificial turf and athletes
At this point you’ll notice that we’ve discussed plastic’s contribution to greenhouse gas emissions and therefore directly to climate change and global warming, as well as pollution and health harms caused by microplastics. We haven’t discussed any of the colorants, stabilizers or other chemicals added to artificial turf such as lead or PFAS [8], nor have we discussed injuries [9][10], heat risks [11][12] or problems with depending upon ‘wet bulb’ readings to assess potential heat stress [11][13][14][15][16].
Regarding heat stress, there are several prediction methods and they have important differences. ‘Wet bulb’ readings differ from ‘Wet bulb global temperature’ readings or ‘simplified Web bulb global temperature’ readings, or from ‘Heat indices’ or from ordinary or ‘Dry bulb’ readings. Since we haven’t discussed this before now, it is worth noting that, though some of the foregoing mechanisms consider atmospheric elements such as wind speed or humidity, none are designed to take into account a significantly hotter underfoot surface temperature.
There are also other issues
Recent studies highlight the importance of humidity in accounting for extreme values of wet-bulb temperature, a proposed indicator of heat stress. However, this result may be sensitive to the measure of heat stress used, which is an ongoing source of confusion.
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It is important to distinguish similar-sounding variables for characterizing heat
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Wet-bulb temperature is very humidity sensitive, WBGT less so, and apparent temperature the least
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WBGT is a more appropriate measure of present-day heat stress, but wet bulb is relevant to tolerance of hotter climates [15].”
About recycling, cost, and government action
Other topics left undiscussed include the fact that artificial turf cannot be recycled in any fashion that resembles sustainable [17][22].
Additionally, while estimates of costs for fields and field types can vary widely, estimates published by non-sports field commercial interests tend to show that, especially when an 8–10-year disposal and replacement cycle is taken into account, artificial turf is more expensive than natural grass [18][19].
Finally, there are more governmental entities, such as cities, towns and even the state of New York, stepping up to the plate or to the pitch, to ban artificial turf. The easiest way to show this is on its own page, so I have added a section below the References.
Though this letter is long, artificial turf is a complex mixed plastic product that, throughout its lifecycle, from petroleum extraction through production, product manufacture, use and disposal, contributes to climate change and harms its users, as well as watersheds and all life along and in those watersheds.
About the Fairgrounds
Though there may never be “enough” soccer fields, every player will be better, healthier and likely happier, playing on natural grass. As a possible partial usage solution for the Fairgrounds Fields, why not have four grass league-play soccer fields, four grass community soccer fields, and two-to-four grass or clay (as for tennis) futsal fields?
Sustainably yours,
Susan Hinton, Lead
Plastic Pollution Prevention Team
Sierra Club Loma Prieta Chapter
References
- 2024, United Nations UN News. Negotiators advance plastic pollution treaty amid ‘extremely ambitious timeline.’ https://news.un.org/en/audio/2024/05/1149251
- 2024, Lawrence Berkeley National Laboratory, Sustainable Energy and Environmental Systems Department. Climate Impact of Primary Plastic Production. https://eta- publications.lbl.gov/sites/default/files/climate_and_plastic_report_final.pdf
- 2020, Princeton University, Princeton Student Climate Initiative. Single-use plastic & alternatives. (Scroll to graph) https://psci.princeton.edu/tips/2020/3/30/single-use-plastic-amp-alternatives
“Plastic production to carbon dioxide released is around a 1:5 ratio ...”
- 2023, University of Barcelona, Spain. The dark side of artificial greening: Plastic turfs as widespread pollutants of aquatic environments. https://www.sciencedirect.com/science/article/pii/S0269749123010965
- 2023, Northeastern University Global News. What happens when sunlight breaks down plastics in the ocean? Potentially harmful chemical byproducts are left behind, research finds. https://news.northeastern.edu/2023/12/05/ocean-plastic-breakdown-sunlight/
- 2023, Waseda University, Japan. Airborne hydrophilic microplastics in cloud water at high altitudes and their role in cloud formation. (Microplastics found in clouds above Mt. Fuji.) https://link.springer.com/article/10.1007/s10311-023-01626-x
- 2024, Harvard Medicine. Microplastics Everywhere. The tiny particles are even in our bodies. What might this mean for our health?
https://magazine.hms.harvard.edu/articles/microplastics-everywhere - 2021, Toxic Use Reduction Institute (TURI). Testing Artificial Turf Materials: Options and Lessons Learned. https://www.turi.org/content/download/13556/206786/file/Report.TestingArtificialTurfMaterials.April2021.pdf
- 2021, Case Western University, Current Orthopaedic Practice 32(4):p 355-360. Injury incidence is higher on artificial turf compared with natural grass in high school athletes: a retrospective cohort study.
https://journals.lww.com/c-orthopaedicpractice/abstract/2021/07000/injury_incidence_is_higher_on_artificial_turf.6.aspx - 2023, NBC and NFLPL. Turf wars: Aaron Rodgers’ injury reignites debate over artificial grass use. Injury rates on turf continue to lead those on grass, but the NFL says the situation is moe complicated.
https://www.nbcnews.com/data-graphics/new-data-shows-nfl-injuries-artificial-turf-stadiums-mostly-exceed-inj-rcna105123 - 2019, University of St. Thomas, Minneapolis, MN. Heat risks associated with synthetic athletic fields.
https://www.tandfonline.com/doi/full/10.1080/02656736.2019.1605096 - 2014, University of Tennessee. Models for predicting surface temperatures on synthetic turf. https://tinyurl.com/mtp8ey3v (Science Direct Assets, long URL)
- 2024, Duke University and NOAA. Observations and Estimates of Wet-Bulb Globe Temperature in Varied Microclimates.
https://journals.ametsoc.org/view/journals/apme/63/2/JAMC-D-23-0078.1.xml - 2022, Purdue University. Explicit Calculations of Wet-Bulb Globe Temperature Compared With Approximations and Why It Matters for Labor Productivity.
https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2021EF002334 - 2018, University of New South Wales, Australia. How Important Is Humidity in Heat Stress?
https://agupubs.onlinelibrary.wiley.com/doi/10.1029/2018JD028969 - 2014. PST Rotronic measuring devices. The Wet Bulb/Dry Bulb Technology. (Simple description of very basic differences between wet bulb and dry bulb measurements)
http://content.rotronic-usa.com/rs/rotronicinstrumentcorp/images/Wet%20Bulb%20-%20Dry%20Bulb.pdf - 2023, Yale School of the Environment, As Plastics Keep Piling Up, Can ‘Advanced’ Recycling Cut the Waste?
https://e360.yale.edu/features/advanced-plastics-recycling-pyrolysis - 2016, Toxics Use Reduction Institute. Sports Turf Alternatives Assessment: Preliminary Results COST ANALYSIS.
https://www.turi.org/content/download/10395/173557/file/Cost%20Artificial%20Turf.%20September%202016.pdf - 2011, City of San Diego Staff Report. Synthetic Turf Cost Benefit Analysis.
https://www.sandiego.gov/sites/default/files/legacy/park-and-recreation/pdf/110303item501b.pdf - 2024, The Philadelphia Inquirer. City officials believed a new South Philly turf field was PFAS-free. Not true, experts say.
https://www.inquirer.com/news/philadelphia/philadelphia-pfas-artificial-turf-field-murphy-recreation-20240223.html - 2024, 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/ - 2024, State of California Department of Justice Attorney General Bonta. Attorney General Bonta Petitions Court to Compel Plastics Industry Association and American Chemistry Council to Fully Comply with Outstanding Investigative Subpoenas.
https://oag.ca.gov/news/press-releases/attorney-general-bonta-petitions-court-compel-plastics-industry-association-and
Examples of government policies on artificial turf
In California
- Millbrae permanent ordinance
https://www.ci.millbrae.ca.us/276/Prohibition-of-Artificial-Turf
- San Marino moratorium through September 12, 2024 (Note: Millbrae had a moratorium for a couple of years before its permanent ban)
In the following web page scroll down to see a link to the moratorium
https://www.sanmarinoca.gov/government/departments/community_development/planning.php
Moratorium
https://cms9files.revize.com/sanmarinoca/O-23-1410%20Extending%20the%20Term%20of%20Ordinance%20No%20O-21-1385-U,%20Establishing%20a%20Temporary%20Moratorium%20on%20the%20Installation%20of%20Artificial%20Turf%20and%20Synthetic%20Grass.pdf
- The city of Sunnyvale passed a resolution to bring a ban to the Council for consideration, and they put a study of artificial turf onto the 2024 Study session list. The Sunnyvale City Council also directed their Parks & Recreation department to put a natural grass athletic field into Lakewood Park rather than an artificial turf field as had previously been planned
- The California Coastal Commission prohibited the University of California Santa Barbara from installing artificial turf due to “potential impacts of the proposed artificial turf, including plastic degradation, microplastic migration, chemical leaching, water quality impacts, and project-related water demand and sustainability aspects, amongst others.”
https://documents.coastal.ca.gov/reports/2023/12/W13.1a/W13.1a-12-2023-report.pdf
In other states
- The State of New York has banned, starting in 2026, artificial turf -and other products- containing PFAS. At the moment this includes ALL artificial turf.
https://dec.ny.gov/environmental-protection/recycling-composting/carpet
"Carpet covered by this law includes, but is not limited to:
Broadloom carpet
Modular carpet tiles
Artificial turf
Pads or underlayment used in conjunction with carpet ...
- July 1, 2026 - Implementation of carpet collection program(s) Producers cannot sell carpet into the state unless participating in a collection program
Retailers may not sell carpet unless the producer of the carpet is participating in a carpet collection program - December 31, 2026 - No carpet offered for sale shall contain or be treated with PFAS substances”
Note the comprehensive definition of PFAS - there’s no wiggle room or arguing over what is or isn’t a PFAS molecule, or over “how much” constitutes a PFAS presence. https://www.nysenate.gov/legislation/laws/ENV/27-3301
Definitions: 8. "'Perfluoroalkyl and polyfluoroalkyl substances' or 'PFAS substances' means a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom."
- Colorado adopted a ban on artificial turf in public and commercial spaces. It does not include athletic fields.
https://www.greenindustrypros.com/irrigation-water-management/article/22893856/colorado-general-assembly-colorado-enacts-bill-to-ban-nonfunctional-turf-installation
“On and after January 1, 2025 the bill prohibits local governments and unit owners' associations of common interest communities from allowing the installation, planting, or placement of nonfunctional turf, artificial turf, or invasive plant species on commercial, institutional, or industrial property, or a transportation corridor common interest community property, or a street right-of-way, parking lot, median, or transportation corridor. The bill also prohibits the department of personnel from allowing the installation, planting, or placement of nonfunctional turf, artificial turf, or invasive plant species as part of a project for the construction or renovation of a state facility, which project commences on or after January 1, 2025.”
The actual ordinance
https://legiscan.com/CO/text/SB005/2024
- East Hampton, MA as updated on July 6, 2023
https://easthamptonma.gov/DocumentCenter/View/119/City-Ordinances-PDF
See section 2.72-2, page 2-12: "With respect to recreational use, the acquisition of artificial turf athletic fields shall be prohibited. (Amended by the City Council on 9-2- 2015; approved by the Mayor on 9-3-2015)"
- Boston, MA October 2022
While not calling it a “ban,” Mayor Michelle Wu halted installation of new artificial turf in a city park. “‘The City has a preference for grass playing surfaces wherever possible,’ a city spokesman said in a statement to GBH News. “There is no ban on the installation of turf in the City of Boston ... That clarification came after the appearance of a single sentence in the reconstruction plans of the city’s Malcolm X Park in Roxbury. A notation in the plan stated: ‘Mayor Wu has directed that no new artificial turf fields will be installed in the City of Boston.’”
- Two New Jersey cities vote to keep AT out of parks (Scotch Plains, Westfield) 2023 November 7, https://www.mycentraljersey.com/story/news/elections/2023/11/07/nj-election-2023-scotch-plains-westfield-turf-fields/71494266007/
“It appears new artificial turf fields will not be coming to Scotch Plains and Westfield, based on unofficial results in Tuesday’s election ... Opponents of the project <s> also cited the high cost, along with health impact from plastic artificial fields and Edison School students losing the majority of their natural outdoor space.”
The European Union
"As from 17 October 2023, Regulation (EU) 2023/2055 restricts synthetic polymer microparticles on their own or intentionally added to mixtures with the aim of reducing the emission of microplastics in everyday products in order to protect the environment ... These types of particles are present in many products such as ... granular infill for use in synthetic sports surfaces (such as rubber substrate for artificial turf sports surfaces)"
https://trade.ec.europa.eu/access-to-markets/en/news/restriction-microplastics-eu-17-october-2023
April 2024 - though not targeting artificial turf, this will affect its use — specifically with regards to production, transportation, disposal
https://www.europarl.europa.eu/pdfs/news/expert/2024/4/press_release/20240419IPR20570/20240419IPR20570_en.pdf
"MEPs adopted their first reading position on the proposed regulation on preventing plastic pellet losses to reduce microplastic pollution"
https://www.europarl.europa.eu/news/en/agenda/briefing/2024-04-22/27/parliament-to-vote-on-stricter-rules-to-reduce-microplastics-losses
"In its 2021 action plan “Towards zero pollution for Air, Water and Soil”, the Commission proposed that, by 2030, the EU should reduce the number of microplastics released into the environment (intentionally and unintentionally) by 30%."