HomeMy WebLinkAboutStaff Report 2508-5070CITY OF PALO ALTO
CITY COUNCIL
Monday, November 17, 2025
Council Chambers & Hybrid
5:30 PM
Agenda Item
9.Approval of the Study and Assessment of Turf Systems: Findings and Recommendation
for El Camino Park Synthetic Turf Replacement as Recommended by the Parks and
Recreation Commission; CEQA status - categorically and statutorily exempt. Staff
Pesentation, Public Comment
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Community Services
Meeting Date: November 17, 2025
Report #:2508-5070
TITLE
Approval of the Study and Assessment of Turf Systems: Findings and Recommendation for El
Camino Park Synthetic Turf Replacement as Recommended by the Parks and Recreation
Commission; CEQA status - categorically and statutorily exempt.
RECOMMENDATION
Staff and the Parks and Recreation Commission recommend that the City Council:
1. Receive and accept the findings and recommendations of the Study and Assessment of
Turf Systems for the City of Palo Alto Playing Fields (Appendix A, Appendix B, Appendix
C, Appendix D, Appendix E, Appendix F); and
2. Direct staff to proceed with replacement of the synthetic turf at El Camino Park in a
manner consistent with the Study’s findings and recommendations.
EXECUTIVE SUMMARY
The Study and Assessment of Turf Systems for the City of Palo Alto Playing Fields provides a
comprehensive evaluation of synthetic, natural, and hybrid turf systems with respect to
playability, environmental health, cost efficiency, and community priorities. The purpose of the
study was to inform future turf replacement decisions, particularly for El Camino Park, where
the existing synthetic field has reached the end of its service life.
Following an extensive data analysis and robust stakeholder engagement process, findings
indicate that synthetic turf offers the most reliable and cost-effective option for maintaining
field capacity and equitable community access at heavily programmed locations, while natural
grass systems present opportunities for long-term improvement through a focused pilot
program. Based on these findings, staff and the Parks and Recreation Commission recommend
that the City Council accept the Study and direct staff to proceed with resurfacing El Camino
Park with synthetic turf consistent with current environmental standards and best practices,
while advancing a parallel pilot to enhance natural grass field performance citywide.
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BACKGROUND
The City of Palo Alto’s Community Services Department manages natural and synthetic athletic
fields citywide, including El Camino Park, Stanford-Palo Alto Playing Fields (Mayfield), and
Cubberley Community Center. The synthetic field at El Camino Park is at its end of life and
requires replacement.
A Capital Improvement Project (PG-24000) to replace El Camino Park’s synthetic turf was
included in the FY 2024 Adopted Capital Budget. However, at the Finance Committee’s May 21,
20241 meeting recommended the City Council direct staff to conduct additional study to
provide informed decisions on future field selections. Focusing on the environmental, health,
safety, and cost impacts of synthetic and natural turf, the study was incorporated into the FY
2025 Budget2.
Additionally, the replacement of El Camino Park’s synthetic turf was placed on hold pending the
study’s findings. Replacement of the Stanford-Palo Alto Community Playing Fields (PG-26000)
was approved June 9, 20253, and is currently underway with completion anticipated in
December, 2025. This phased approach helps maintain field availability while the study
progresses. The goal is to provide the City Council with the necessary data needed to make
informed decisions about future field installations and renovations. The report includes sixteen
sections encompassing acknowledgments, background, community feedback, data analysis, and
topic-specific findings. These sections address playability, life cycle costs, health and
environmental impacts, City park inventory and field availability, a case study of El Camino Park,
and supporting materials such as a glossary, references, and appendices.
The Santa Clara County Board of Supervisors considered prohibiting new installation of
synthetic turf on County property in January 2025. The report included a Public Health
Department Review of Scientific Literature of the potential health risks associated with artificial
turf.4. To avoid duplication of effort, the City’s scope of work was adjusted to incorporate the
County’s findings on environmental and health impacts. The community engagement and
maintenance components of the study were conducted by City staff. This item was first
scheduled to be discussed at the August 26, 2025 Parks and Recreation Commission meeting5,
1 Finance Committee, May 21, 2024; Agenda Item #1; SR# 2402-2664,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=543c404f-2b05-4cbb-b9df-75ffb768545d
2 City Council, June 17, 2024; Agenda Item #28; SR# 2406-3140,
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=82926
3 City Council, June 9, 2025; Agenda Item #9; SR #2501-3998,
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=83440
4 Santa Clara County Board of Supervisors, January 28, 2025, Agenda Item #13, SR# 122722;
https://sccgov.iqm2.com/Citizens/Detail_Meeting.aspx?ID=16789
5 Parks and Recreation Commission, August 26, 2025, Agenda Item #6, SR# 2508-5075,
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=17508
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however,only public comment was heard due to the late hour, and this item was placed the
following month’s agenda.
11, the Parks and Recreation Commission heard a staff presentation,
reviewed the Draft Turf Study and provided feedback. On October 28, 202512 an updated draft
returned to the Parks and Recreation Commission for a recommendation to the City Council.
ANALYSIS
11 Parks and Recreation Commission, September 23, 2025, Agenda Item #4, SR# 2509-5208,
12 Parks and Recreation Commission, October 28, 2025, Agenda Item #5, SR# 2510-5333,
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require greater capital investment, requiring about $3.5 million for a synthetic turf field over 20
years compared to $1.8 million for a native-soil natural grass field. In contrast, natural grass
fields are less expensive to construct, but offer lower playable hours and require higher ongoing
maintenance, resulting in $179-$203 per hour when utilized within their carrying capacities.
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Based on the study’s findings and the Parks and Recreation Commission’s deliberations, staff
and the Commission recommend resurfacing El Camino Park with synthetic turf consistent with
current environmental standards and best practices, while concurrently implementing a pilot
program to enhance the playability and carrying capacity of the City’s natural grass fields.
Maintain short-term field capacity and ensure continued community access.
Engage an agronomy expert to refine maintenance practices, establish measurable
performance benchmarks, and identify opportunities to optimize performance of
existing native-soil fields and expand or enhance natural grass field inventory.
Support long-term field management and capital planning decisions that incorporate
higher-performing natural grass systems as technology, research, and policy evolve.
FISCAL/RESOURCE IMPACT
fields through improved soil health, turf cultivar, drainage, and irrigation practices; 2.
Implementation of higher-performing sand-based field profiles to evaluate durability and
playability under intensive use and seasonal conditions; and 3. Integration of additional natural
grass fields into the City’s athletic inventory to meet current and future demand. The specific
cost of this pilot will depend on the number of test sites, scope of agronomic evaluation, and
level of maintenance adjustment undertaken. The costs would be refined during program
development and could be funded through future operating budgets or existing park
maintenance allocations.
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Alternatively, if City Council directs staff to replace El Camino Park with natural grass, staff
estimates the project would require 18 months or longer for design, procurement, removal,
and installation, at a cost between $1.5 million and $2.0 million. In either scenario, the project
will require a future budget adjustment at the Mid-Year Budget Review.
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
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specific project or allocate funding for such project. CEQA review of specific turf replacement
projects will occur as required by law.
ATTACHMENT
APPROVED BY:
Parks Recreation Commission
Page 1 of 3
DRAFT ACTION MINUTES
Regular Meeting
October 28, 2025
The Parks & recreation Commission of the City of Palo Alto met on this date in the Council
Chambers and by virtual teleconference at 6:00 P.M.
Present In Person: Shani Kleinhaus, Jeff Greenfield, Nellis Freeman, Anne
Cribbs, Yudy Deng (arrives 6:12, Left 10:30)
Others Present: Julie Lythcott Haimes (arrived 6:25) (left 9:43 PM)
Present Remotely:
Absent: Commissioner Bing Wei , Commissioner Amanda Brown
Call to Order
Public Comment
Agenda Changes, Additions and Deletions
Approval of Minutes
1. Approval of Draft Minutes from September 23, 2025, Parks & Recreation Regular Meeting
MOTION:Commissioner Cribbs moved, seconded by Vice Chair Greenfield to approve
Agenda the minutes
MOTION PASSED: 5-0-2 ,Brown, Wei absent
DRAFT ACTION MINUTES
Page 2 of 3
City Official Reports
1. Council Liaison Report – 5 minutes
NO ACTION
2. Department Report – 20 minutes
NO ACTION
3. Ad Hoc Committees and Liaison Updates (Discussion) – 15 minutes
ITEM HEARD OUT OF ORDER AFTER ITEM # 7.
NO ACTION
Business Items
4. Review and provide feedback on the Foothills Nature Preserve Improvements Project Scope
Reduction – 60 minutes
5. Study and Assessment of Turf Systems: Findings and Recommendation for El Camino Park
Synthetic Turf Replacement – 90 minutes
MOTION: Vice Chair Greenfield moved, seconded by commissioner Cribbs to accept staff
recommendations with the addition of moving the risk mitigation measures (RMM) plan back into
the general recommendations.
Staff recommend that the Parks and Recreation Commission recommend that the City Council
accept the findings and recommendations of the Study and Assessment of Turf Systems for the City
of Palo Alto Playing Fields and direct staff to proceed with replacement of the synthetic turf at El
Camino Park in a manner consistent with the Study’s findings and recommendations.
MOTION PASSED: 4-1-2, Kleinhaus no, Brown, Wei absent
6. Update on Ad Hoc Nature Policy and Proposal Trail Closure Pearson Arastradero Preserve –
45 minutes
7. Update on the Baylands Comprehensive Conservation Plan (BCCP) – 45 minutes
8. Recognition of Service for Commissioner Cribbs, Greenfield, and Freeman (Pending
Reappointment)
ITEM HEARD OUT OF ORDER AFTER ITEM #1
NO ACTION
DRAFT ACTION MINUTES
Page 3 of 3
Commissioner Questions, Comments, Announcements or Future Agenda Items
Adjournment: The meeting was adjourned at 11:44 P.M.
STUDY AND
ASSESSMENT OF
PALO ALTO TURF SYSTEMS
City Council
November 17, 2025 www.PaloAlto.gov
BACKGROUND
Community Services manages four synthetic fields at three locations
•El Camino Park (1)
•Stanford Palo Alto Community Playing Fields (Mayfield) (2)
•Cubberley (1)
Turf replacement projects
•El Camino – Design - 2024/Construction – FY26 (Construction Deferred)
•Mayfield – Design/Construction (In construction; Estimate Completion: Dec 2025)
•Cubberley – 2028
Council directed staff to pause El Camino Park Turf Replacement Project and redirected
project funding for a turf study.
TURF STUDY
Study objectives
•Evaluate turf for athletic fields
•Focus on environmental and health considerations, cost,
and usability
•Adjusted scope to incorporate the SCC Public Health
Report released 1/28/25
•Case Study: El Camino Park
Combination of staff and consultant expertise provides a
balanced approach of local knowledge and comprehensive
analysis.
Overall, the study will provide support for data-driven decision-
making for future athletic field replacements.
TURF STUDY SCHEDULE
Project Webpage: www.PaloAlto.gov/TurfStudy
Estimated Project Schedule:
June 2025: Project Launch
July 2025: Focus Groups with Park and Recreation Commission Playing Field Ad Hoc, Field Users, and Sierra Club
August 13, 2025: Draft Report Released
August 13 – September 3, 2025: Community Engagement Comment Period on Draft Report
August 26, 2025: Parks & Recreation Commission Meeting (Item was not discussed, too late in the evening)
September 23, 2025: Parks and Recreation Commission Meeting
October 28, 2025: Parks and Recreation Commission Meeting
November 17, 2025: Report and Presentation to City Council
= completed
= current
PALO ALTO TURF STUDY
OVERVIEW
•Field System Types
•Playability & Carrying Capacity
•Cost
•Health and Environmental
•Draft Study Comments and Revisions
•Recommendations
PALO ALTO TURF STUDY
SYSTEMS
•Natural Grass Systems
•Synthetic Turf Systems
•Hybrid Systems
Natural Grass
(City Fields)
Natural Grass Synthetic Turf
(City Fields)
Hybrid System
Native Soil Sand Rootzone
Drainage
Aggregate Base &
Drainage Sand Rootzone
Drainage
Synthetic & Natural Grass
PALO ALTO TURF STUDY
PLAYABILITY AND CARRYING CAPACITY
•The City’s fields are heavily programmed
throughout the year for youth leagues, adult
sports, school use, and community recreation.
•Playability is the extent to which a field reliably
supports athletic and recreational activity while
maintaining safe, consistent, and serviceable
surface conditions.
•Natural grass fields carrying capacity; maximum
amount of use a field can sustain before its
condition declines to a level deemed unacceptable
for safe or quality play.
•Synthetic Turf Fields >2,500 annual hours.
Cubberly multipurpose and Greer Fields >1,000
annual hours.
PALO ALTO TURF STUDY
COST EFFICIENCY
•Over a 20-year period and when fields meet their carrying capacity, synthetic turf provides the
lowest cost per hour of use at approximately $79 per hour, while natural grass ranges between
$179 and $203 per hour.
•Synthetic Turf is more expensive to build, but less expensive to maintain.
•Hybrid Turf Systems have the highest combined installation and maintenance costs among all
field types.
PALO ALTO TURF STUDY
HEALTH AND ENVIRONMENTAL
•Microplastics in synthetic turf originate from both the turf fibers and the rubber or plastic
infills. These microplastics enter the environment in three primary ways:
(1) by adhering to athletes and equipment, typically in the form of infill;
(2) through maintenance activities such as grooming and sweeping, with collected material
often disposed of as regular refuse; and
(3) via environmental forces such as rain and wind.
•Natural or organic (non -plastic) infills can reduce microplastic migration into the
environment.
•PFAS thresholds are still being evaluated and cover a wide range of products. Currently there
is not an industry standard for PFAS thresholds, thus “PFAS reduced” or “PFAS free” rely on
testing scope, detection limits, and definitions provided by the certifying body or
manufacturer.
PALO ALTO TURF STUDY
DRAFT STUDY PUBLIC COMMENTS
•21 Unique Contributors Responded: Organizations,
Residents, and Non-Residents
•Health and Environmental Concerns: PFAS,
Microplastics, Surface Heat, and End-of-Life
Recycling. Interest in optimizing Natural Grass Fields.
•Use Hour Methodology: ½ Field vs Full Field Rentals
•Recreation User Groups: Support Synthetic Turf as it
provides better Playability, Meets Program Demands,
and Flexibility
PALO ALTO TURF STUDY
GENERAL RECOMMENDATIONS
•Synthetic turf at El Camino Park is at end of life and needs to be resurfaced or replaced with natural
grass.
•Replacing with natural grass would cost $1.5m - $2m and the project would take 18 months to
complete. It would also reduce the capacity of the field and programming would be impacted.
•Replacing with synthetic would maintain existing program but not address health and environmental
concerns.
•Consider resurfacing with synthetic turf while a pilot program is implemented to further optimize
existing natural grass fields and add additional fields to inventory to maintain capacity .
RECOMMENDATIONS
Staff and the Parks and Recreation Commission recommend that the City Council:
1.Receive and accept the findings and recommendations of the Study and
Assessment of Turf Systems for the City of Palo Alto Playing Fields; and
2.Direct staff to proceed with replacement of the synthetic turf at El Camino
Park in a manner consistent with the Study’s findings and recommendations
SARAH ROBUSTELLI
Division Manager Open Space, Parks, and Golf
sarah.robustelli@paloalto.gov
(650)617-3518
ANTHONY STEVENSON, PE
Principal at Lloyd Consulting Group
info@lloydengineers.com
From:Robert Hall
To:Council, City
Subject:Public comment, Item 9: Turf Systems Assessment
Date:Monday, November 17, 2025 11:04:48 AM
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RE: 9. Approval of the Study and Assessment of Turf Systems: Findings and
Recommendation for El Camino Park Synthetic Turf Replacement as Recommended by
the Parks and Recreation Commission; CEQA status - categorically and statutorily
exempt.
Dear Members of the Palo Alto City Council:
Thank you for the opportunity to comment on the turf-field replacement decision before you—
particularly the discussion regarding the fields at El Camino Park and the broader implications
of synthetic (“artificial”) turf versus natural grass in our city parks.
I urge you to reject the installation of new artificial turf and instead embrace well-managed
natural grass that better aligns with the City’s sustainability, health and long-term-cost goals.
My comments are informed in part by the City’s recently released turf study on synthetic vs
natural athletic fields. paloalto.gov+2paloalto.gov+2
Key reasons why artificial turf is the wrong choice for Palo Alto:
1.Environmental and health risks from plastics, infills and micro-pollutants.
Synthetic turf is made of plastic fibres and infill materials (often rubber, sand,
cork, or other options) which degrade over time and can release micro-plastics,
rubber granules, and chemical additives into the surrounding soils, drainage, and
air. Wikipedia+1
The City report specifically raises concerns about emerging chemical issues (for
example PFAS/“forever chemicals”) in synthetic turf installations. San José
Spotlight+1
Unlike natural grass, synthetic turf offers no ecosystem service of soil-
sequestration, transpiration cooling, or biotic soil life. Once installed, it acts as an
impermeable or semi-impermeable surface with less ecological benefit.
2.Life-cycle, disposal and long-term cost issues.
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While artificial turf may appear to reduce mowing or watering in the short term,
the long-term costs (replacement of the turf carpet, disposal of worn-out synthetic
mats, infill replenishment, seam repairs, etc.) are significant and often under-
accounted for. The City’s own study emphasizes a life-cycle cost analysis of the
alternatives. paloalto.gov+1
Disposal of synthetic turf is problematic: many turf fields are only usable for a
defined lifespan (e.g., 8-12 years), and the worn-out materials often go to landfill
or worse. The study advises that the City considers end-of-life management in its
evaluation. paloalto.gov
3. Reduced ecosystem services and climate resilience.
Natural grass contributes to cooling (via evapotranspiration), infiltration of storm
water, carbon sequestration (albeit modest), and supports soil microbial life. In a
warming climate and with storm-water/run-off concerns, natural turf is more
aligned with sustainability goals.
Artificial turf surfaces absorb solar heat and raise local surface temperatures
significantly compared to grass, thereby increasing urban heat island effects and
making fields less comfortable, especially during hot summer afternoons.
4. Maintenance, injury and field-use trade-offs.
Some proponents of synthetic turf argue the ability to support very high-use
athletic scheduling. However, I would caution: higher usage means greater
degradation, faster heat exposure, and ultimately faster replacement.
The City of Palo Alto study acknowledges that greater hours of play on synthetic
turf must be weighed against durability and health concerns. paloalto.gov+1
While natural grass does require thoughtful maintenance (irrigation, mowing,
aeration, rest periods), Palo Alto already has a strong parks program and
community capacity to maintain grass fields sustainably, especially given our
mild climate and local water-efficiency advances.
5. Alignment with Palo Alto’s sustainability values and policies.
The City has committed to strong climate, zero-waste, and environmental justice
goals. Choosing a plastic-based field replacement runs counter to these values: it
places a heavy-plastic, high-energy, disposal-intensive infrastructure at the heart
of a public park.
In light of the study’s recommendation to include “compatibility of field options
with Palo Alto’s broader sustainability and climate action goals” in the evaluation
process, the decision to go synthetic must show strong, defensible rationale that it
does more good than harm. San José Spotlight+1
Why natural grass is the better choice for Palo Alto:
With proper drainage, irrigation, soil health programs (compost, organic amendments),
supports athletics and ecological health.
Natural grass supports the goals of open-space parks—not just as athletic fields—but as
green infrastructure, air-cooling, neighborhood amenity, and place for community
relaxation.
It avoids the plastic burden, avoids disposal issues, and keeps us aligned with a longer-
term mindset (not just “install now, dispose in 10 years”).
Maintenance costs can be stabilized through best practices (reduce water use via
drought-tolerant species, smart irrigation, turf-grass blends suited for our climate) and
the City can invest in monitoring and adaptive management rather than overseeing a
plastic carpet replacement treadmill every decade.
Recommendations for the City Council to adopt:
Before approving any synthetic turf installation, require a full life-cycle cost and
environmental impact comparison (including manufacturing, transport, installation,
maintenance, disposal) between synthetic turf and a best-practice natural grass rebuild
(or hybrid system). The City’s own study provides this framework. paloalto.gov
Prioritize field redesign so that natural grass becomes the standard unless a very
compelling case is shown that synthetic turf offers significantly greater public benefit
and minimal environmental trade-offs.
If synthetic or hybrid turf is proposed, ensure stringent specification of materials (low or
zero PFAS infill, guaranteed recyclability, documented disposal/recycling plan, heat-
mitigation design) and full disclosure of usage hours, maintenance costs, expected
lifespan, and replacement/disposal.
Invest in ongoing soil health and turf-grass management programs so that natural grass
fields in Palo Alto become long-lived, high-functioning assets rather than planning for
frequent replacement.
In conclusion: The choice of field surface is not just a “mowing vs no mowing” operational
question—it is a substantive sustainability decision for the City of Palo Alto. By choosing
natural grass over plastic-based artificial turf, the City will uphold its environmental
leadership, reduce long-term risk and cost, deliver athletic fields that serve the community and
the climate, and avoid the hidden burdens of plastic infrastructure. I strongly urge the Council
to direct staff to prioritise natural grass rebuilds for El Camino Park (and other City-owned
fields) and to only consider synthetic turf as an exception after rigorous comparative analysis.
Thank you for your time and for your leadership in stewarding Palo Alto’s parks for present
and future generations.
Bob Hall
San Francisco, 94117
From:Pam Bond
To:Council, City
Subject:Public Comment Action Item 9, Approval of the Study & Assessment of Turf Systems
Date:Monday, November 17, 2025 10:30:00 AM
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Dear Palo Alto City Councilmembers,
Please see attached my comments regarding the Study and Assessment of Turf Systems. Consider the full life
cycle of the plastic journey from manufacture to end of life. I am sharing local examples of plastic blade
loss and storm water pollution in hopes that you will carefully consider the environmental harm that these
plastic fields perpetuate.
Sincerely,
Pam Bond
2025.11.17 Palo Alto City Council - caution regar…
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This is their first email to you.
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From:Claire E
To:Council, City
Subject:El Camino Park Turf causing Plastic Pollution
Date:Monday, November 17, 2025 9:49:49 AM
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Dear Council members,
I sent you a list of concerns related to the Lloyd study and installation of more synthetic turf at
El Camino Park (see below.) Today I am sending photographs I took at El Camino Park. It had
recently rained but was not raining at the time. So no water was running toward the storm
drain but it was clear that plastic grass blades were migrating off of the field and into the storm
drain.
Photos below include a Google map image with the storm drain labeled. In the following
photos, you can see the plastic grass blades migrating across to DG path, collecting in fall
leaves, and on the storm drain grate. Many had also entered the drain and it is certain that a lot
had already entered a creek. On the map image you can also see El Palo Alto, the namesake
tree of Palo Alto on the banks of San Francisquito creek. So although it is an urban area, there
are important ecosystems to protect from plastic and its toxic components, as well as human
health.
Thank you for your time and attention,
Claire Elliott
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This is a personal email address.
Mark Safe Report Powered by Mimecast
1.
Lloyd study should not be approved in its current biased and incomplete form:
a.
A large concern is the poor attention paid to the health impacts of synthetic
turf.
i.
The “Heath Hazards” section lists one chemical hazard for synthetic
grass (PFAS) and several for natural grass, even though the chemicals
listed for natural grass are all pesticides that Lloyd must know Palo Alto
does not use.
1.
The report downplays the PFAS concern by saying the city can
procure PFAS free turf.
a.
This is a serious problem because it is not yet possible to
confirm any product is PFAS free, due to the large number of
PFAS compounds that could be incorporated into feed stocks
used by the turf manufacturer.
b.
Many of these compounds have no approved analytical
method to identify their concentration in a material.
ii.
In addition, synthetic turf often contains a large number of compounds
besides PFAS that are known to be toxins, carcinogens and endocrine
disruptors.
iii.
Also during its use, plastic grass blades often break off and then turn into
microplastics which are known to have many negative health and
environmental impacts.
b.
A second concern is uneven focus of environmental concerns for all three turf
types evaluated by the study.
i.
No more mention of PFAS is made, in this case the only concern about
synthetic turf is the release of microplastics.
ii.
For hybrid and natural grass, carbon footprint and water use were
described, but not for synthetic turf even though its carbon footprint is
high and water is used in washing and cooling the turf. Sometimes
antibacterial solutions are also used which can be released into the
environment.
iii.
No other chemical releases form synthetic grass is mentioned (like health
impacts they should have include the thousands of chemicals that can be
included and leached out of synthetic turf, including many that are toxins,
carcinogens and endocrine disruptors.
c.
The cost figures are also misleading in the final report.
i.
The cost per hour calculated for natural grass fields assumes these fields
are only used for an average of 500 hours per year when the study itself
lists nine grass fields in Palo Alto that are currently used over 1,000
hours per year.
ii.
The cost per hour for synthetic turf assumes El Camino was used for
2700 hours per year. This calculation included some “double-dipping”
because when the two halves of the field were used at the same time,
two instead of one hour was used. The consultant admitted if this method
is changed, the usage would be 1,900 instead of 2700 hours per year. It
should be changed because the cost for installing and maintaining the
fields is based on the full sized field, not half of a field!
iii.
When you redo the cost estimate per hour of usage, these corrected
numbers result in the cost per hour for grass changing from $179 to $89
and synthetic turf changing from $79 to $92. Showing natural grass can
cost less.
iv.
The cost for synthetic turf would go up further from $92/hour of play
if you include the cost for recycling the turf which was left out of the
study.
v.
The cost for synthetic turf would go up even farther if the study included
an estimated cost for the environmental and health impacts of synthetic
turf during manufacture, use and disposal.
vi.
In the October 28th Parks and Recreation meeting, the Lloyd consultant
stated that recycling turf is expensive so the turf might be repurposed for
batting cages, as substrate for horse arena soils or shipped south of the
border. What is the eventual fate of these “repurposed” turf fields?
vii.
What is the economic impact of synthetic turf chemicals and
microplastics in our soil and waterways, the cost to clean up
contamination caused by reuse and disposal, or the price of medical bills
and shortened life spans for those in plastics manufacturing industries
who are known to have significantly higher cases of many diseases?
2.
One recommendation of the Lloyd study that makes a lot of sense is to design and
implement a pilot project of a well-designed and maintained grass field.
a.
This would allow Palo Alto to gather data to compare costs and carrying
capacity of a high quality organic grass field with drought resistant grasses and
good surface drainage. These types of fields have been shown in other parts of
the country and world have provided up to 2,000 hours of use per year.
b.
This pilot project would be ideally implemented now at El Camino Park. The
design could start this year and by installing sod instead of seeding you could
shorten the project timeline.
c.
The lighted field at El Camino would also allow extended play many grass fields
in Palo Alto do not offer.
d.
Saying no to plastic grass and implementing a natural grass pilot project would
help Palo Alto maintain a reputation as an environmental leader and avoid the
well known environmental and human health impacts of a synthetic field before,
during, and after its useful life.
3.
The Lloyd study gives little detail about what a pilot project design should include.
Some ideas include:
a.
Partner where possible with the county, other cities in the region, school
district, etc, so the costs and results can be shared regionally.
b.
Develop the plan with expert help of agronomists who have already had
success designing and maintaining organic grass fields. Beyond pesticides
may be able to provide some of this expert help at no or low cost to the city.
c.
Save money and water and make organic management more successful by
NOT using a sand capped field. Provide internal drainage by amending the
native soils with organics, and aerating often. Provide surface drainage with
careful grading that provides a smooth surface with a slight crown in the
middle.
d.
Include high efficiency irrigation (e.g. MP rotators) to mimic rainfall and reduce
drift and puddling of water.
e.
Selects a grass species that has been shown to allow additional play time
(possibly a warm season grass that has been shown to work in California.)
f.
Use organic management that adds carbon and nutrients that are less likely to
runoff into stormdrains.
g.
Grass field monitoring and maintenance is critical. Increase the budget for
these necessities. Ensure contracts for maintenance are detailed, hold back
funding to ensure the contractor performs well.
h.
Control gophers and fill holes and ruts caused by animals, people, vehicles,
etc.
i.
Ensure maintenance protocols are detailed in contracts and funding held aside
until contractors prove they are following the required protocols. Ask for logs of
maintenance and photo documentation of improvements made.
j.
Develop an easy to access and use crowd sourcing method of evaluating field
conditions (online tool for reporting gopher holes, irrigation problems leading to
dry or soggy conditions, etc.
k.
Use adaptive management to alter practices as results from monitoring show
improvements are needed.
From:Alice Smith
To:Council, City
Subject:Artificial Turf
Date:Sunday, November 16, 2025 8:56:17 PM
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
I urge the city of Palo Alto to ban artificial turf anywhere in city owned property in Palo
Alto: not only on playing fields, , at parks, everywhere. We need to stop runoff with
poisonous chemicals, let the earth breath and allow worms, bugs and grass to be part
of our landscape, enhancing the quality of our town.
We should ask our community members to change from grass to wild grasses if
practicable, and to remove artificial turf because the turf is polluting the streams,
increasing runoff and killing the natural soil under it.
We re supposed to be an environmentally aware city, proud of our certifications for
new buildings, but then you put chemicals down instead of grass and pollute our
streams, expose children to dangerous chemicals. Why? Because you might not
have to mow grass and keep it growing.
"Turf is harmful to health, safety, and the environment. It contributes to urban heat
as turf field surfaces can get anywhere from 40-70 degrees Fahrenheit hotter than
surrounding areas on hot days. Because of this, injuries such as turf burn and heat
stroke are more common on artificial turf fields.
Additionally, artificial turf contains harmful chemicals such as PFAS, a class of toxins
linked to cancer and reproductive harm which can be dangerous to users
of artificial turf fields. Artificial turf also poses a threat to the environment and aquatic
wildlife when chemicals like PFAS and particles like microplastics get washed into our
waterways.
By banning new artificial turf on city land and using natural grass fields instead, the
county can protect people and the environment." (Save Our Bay)
Alice Schaffer Smith
850 Webster Street #520
Palo Alto, CA 94301
650 283 2822
From:Leanne McAuliffe
To:Council, City
Subject:(Frustrated) Public Comment - Meeting Nov. 17, 2025 - Action Item 9, Approval of the Study & Assessment of
Turf Systems
Date:Saturday, November 15, 2025 10:49:49 AM
Attachments:TigerTurf-Championship-Plus-1.625-in-56-oz-Spec-Sheet.pdf
Pivot specs.pdf
Brown lead n1782_astroturf_cj,_final-signed (1).pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
i
Dear Palo Alto City Councillors,
Below is an email I sent to Parks and Rec. In summary:
There is a standard for lead of <50 parts per million for artificial (plastic) turf in
California.
Some in the plastic turf industry are defining "non-detectable" for lead as <100 parts per
million.
Simple math shows 100 parts per million is double the California standard for plastic
turf.
The Parks and Rec response to my simple math was that they (consciously) didn't include lead
in the report and that "lead thresholds for synthetic turf have been established by the State."
So it seems they did not even read my email. I know there is a threshold BUT for some
products there's no sure indication these thresholds are being met!! And NO ONE is keeping
the plastic turf industry in check. The plastic turf industry is self-regulating!
So, as Councillors who make the final (conscious) decision on this report, please SIMPLY
require that the Final Turf Report include:
the health impacts of lead on children and why they are more vulnerable to toxic
effects,
the California state standards for lead in artificial turf,
the attached Consent Judgment in the report's appendix.
In line with this please then use your power to protect our kids and require that ALL (if any)
artificial turf components selected for Palo Alto City MUST be under the 50 parts per million
lead limit in line with the California standard and that this must be proven with lab reports
This message needs your attention
This is a personal email address.
Mark Safe Report
precautionary measures for our kids, demand the lead limit be set to zero parts per million
given that the CDC has stated "NO safe blood lead level in children has been identified and the
effects of lead exposure cannot be corrected." Please do not let the issue of lead fall under
the radar.
Even better still, avoid unnecessary exposure to any lead, PFAS, microplastics or any cocktail
of other chemicals in plastic turf and chose real turf for field replacements and renovations.
What you ultimately decide will not only protect children and youth in your own city but also
those in surrounding cities and towns that will follow your lead.
Kind regards,
Leanne McAuliffe
Santa Clara county resident
From: Leanne McAuliffe <leannemcauliffe@hotmail.com>
Sent: Wednesday, September 3, 2025 1:09:06 PM
To: Kristen.O'Kane@paloalto.gov <Kristen.O'Kane@paloalto.gov>;
parkrec.commission@paloalto.gov <parkrec.commission@paloalto.gov>
Subject: Synthetic Turf and Natural Grass Turf study - Draft Report - Please incorporate lead
standards
Dear Palo Alto City Community Services Director Kristen O’Kane and Parks and RecreationCommission Chair Nellis Freeman,
With regard to the Turf Study Draft Report, please include lead in this draft report and set a
standard that either requires artificial turf products have ZERO lead in them or that they at
least have <50ppm (less than 50 Parts Per Million).
The only reference to lead that I can find in this entire draft report is in the appendix in a
County of Santa Clara, Office of The County Executive communication to the Board of
Supervisors. See pages:
- 663 (& 739 where the same document is repeated) where there is reference to the fact
there is no safe level of blood lead.
- 701 (& 777 again in repeated document) where lead was found in tire crumb infill above CA
DTSC levels and EPA regulatory limits.
This is disturbing because lead has been a huge issue for artificial turf in the past and it should
not be left to fall completely off the radar. (Lead issues do not only apply to the tired crumb
rubber infill so removing this as an infill option doesn't necessarily remove the lead risk.)
Lead was found in artificial turf at dangerously high levels and as a result a standard for
artificial turf was set in 2009 by then Governor Brown limiting lead in artificial grass carpet to
<50ppm from 2010 (with an exception ONLY for field lines of <100ppm). However, some
companies apply <100pm to their entire product and at times even equate this to "lead free".
As a concerned parent and consumer, I would expect "lead free" to mean ZERO lead. Anything
other than that should be transparently defined to allow informed consumer choice. Likewise,
anyone using the final version of this draft report should be able to make a fully informed
judgement and decision.
Some products are confusing when it comes to lead content. For example, TenCate, who have
been promoting their latest product, Pivot, have lab reports simply stating that Pivot has
<100ppm lead content. This doesn't meet the <50ppm standard set by Governor Brown. In
the event that the Pivot product actually has less than 50ppm, Tencate were asked months
ago to define exactly how many ppm of lead the Pivot product has but no answer was
received. Likewise, Tiger Turf is marketed as lead free and yet lab reports simply state
<100ppm lead content. Always Green Company even inaccurately states the standard to be
<100ppm with a certificate stating Tiger Turf to be "Lead Free" but the certificate itself defines
this as no "detectable" traces of lead. Does this just mean no lead detected over 100ppm since
lab reports simply state the lead level to be <100ppm? This alone would not meet the <50ppm
standard.
We all know that lead is a huge problem when it comes to children's health and the CDC has
stated "NO safe blood lead level in children has been identified and the effects of lead
exposure cannot be corrected." Given how much artificial turf can disintegrate over time, any
lead content in artificial turf is concerning. Hence, the safest level is really zero.
Since the report is about being proactive and not reactive please don't allow scenarios like
that in New Jersey in 2012 reoccur. Back then extremely unsafe levels of lead had been found
in plastic grass fields. At that time only 5 of 50 schools allowed their fields to even be tested
for lead. So 45 refused? Basically, it seemed school funds took priority over children’s health.
We can’t have this happening again with any toxin be that lead, PFAS or any other chemical
for that matter.
When looking at El Camino Park, have funds already dictated decisions? I was at this park on a
cloudless May morning at 11am and the temperature was only F65 and yet the artificial turf
field was already F129.5. Even on this cool morning the smell of the field was nauseating. I
could not imagine what it was like for kids/youths playing on that field in those temperatures
let alone warmer temperatures. I appreciate the original infill was a disaster and that it was
"fixed" but there was still a lot of the original infill in the field even all after those years, so was
it really "fixed" sufficiently? Or did funds dictate how well the issue could be addressed?
So, in line with making the draft report as robust as possible to avoid issues for users, the
environment or public funds, please also incorporate some basic lead information and
standards into this report for all artificial turf components (preferably ZERO, but at minimum
<50ppm) especially since the primary users, kids and youths, are also the most vulnerable to
the effects of any toxins.
Kind regards,
Leanne McAuliffe
Santa Clara Resident
(Though I am not a Palo Alto resident I know my own town, Los Gatos, has eagle eyes on this
report so it is incredibly important to me that your report more robustly protects our kids and
youths.)
SIDE NOTE: the attached TenCate document markets the Pivot product as no infill, no microplastics, no PFAS, but:
"no infill"? (they also state later that a cooling infill is available to help deal with heat issues - Santa Clara County has
a hot climate),
"no microplastics"? (if you visit John Mise Park you'll see a whole lot of microplastics from the Pivot field there),
and
"no PFAS"? (on TenCate's website it says artificial turf has less than 100ppm PFAS which does not equal "no" PFAS)
Just like other industry claims like "lead free" these statements cannot always be taken at face value.
https://oag.ca.gov/news/press-releases/brown-creates-nations-first-enforceable-lead-
standards-artificial-turf
Brown Creates Nation's FirstEnforceable Lead Standards forArtificial Turf - State of California -Department of Justice - Office of theAttorney General
OAKLAND-Fighting to ensure the safety of children’splaygrounds and ball fields, Attorney General Edmund G.Brown Jr. today signed off on an agreement requiringGeorgia-based AstroTurf, LLC to virtually eliminate leadfrom its artificial grass, creating the country’s firstenforceable lead standards for artificial turf products. “Asschools and daycare centers replace grass with ...oag.ca.gov
https://alwaysgreensyntheticgrass.com/artificial-grass-safe-families-pets/
https://peer.org/lead-limits-needed-on-tire-crumb-playgrounds/
Lead Limits Needed on Tire CrumbPlaygrounds - peer.org
Lead Limits Needed on Tire Crumb Playgrounds CPSCRuling on Artificial Play-Areas as Children’s ProductsSought Washington, DC — The Consumer ProductSafety Commission (CPSC) should prevent children frombeing exposed to lead and other harmful heavy metals inplaygrounds and school sports fields made fromshredded tires, according to a formal request for anadvisory opinion filed by Public ...peer.org
Combining durable XPS slit film and playable Diamond
monofilament fibers with thatch at the base, players
get a heavier, more consistent playing surface.
The texturized monofilament thatch helps to reduce infill splash, decrease infill
migration and provide additional shock absorption. Teams will enjoy a field that not
only looks great, but feels and plays great, as well.
CHAMPIONSHIP+
TENCATE GRASS | 1131 BROADWAY ST. DAYTON, TN 37321 | (855) 773-6668 | VERSION 2023
TIGERTURF CHAMPIONSHIP+ SPECS
YARN
DENSITY (DENIER) 10,000/1 (XPS),
12,000/6 (XWRD),
5,000/8 (thatch)
THICKNESS (MICRONS) 120 (XPS); 365 (XWRD),
100 (thatch)
MELTING POINT 128° C | 260° F
BREAKING STRENGTH 24 lbs/force (XPS/XWRD);
LEAD CONTENT (PPM) <100
Pile Height, Max Thickness, Face Weight, Primary & Secondary Backing, and Total Weight can differ by ±10%. The Stitch Rate will change according to the exact
specifications and can differ by ±1. Roll Width can differ by ±0.8 inch.
TenCate Grass has the right to alter each product specification in order to improve the system according to the latest standards. TenCate Grass is not legally liable in case
of noncompliance with the above mentioned specifications.
*Face Weight reflects entire length of yarn, including portion woven into backing, which is consistent with standard ASTM method of measuring tuft including back stitch.
**For details on thatch color, refer to the Standard Color Sheet. ***Lime Green is shown for color reference only. Lime-only turf is not available.
BEST FOR BASEBALL,
SOFTBALL, INDOOR AND
MULTI-PURPOSE FIELDS
TURF
PILE CONTENT TenCate U.V. resistant XWRD,
monofilament and TenCate U.V. resistant
XPS Plus slit film combined with
TenCate TXT monofilament
root zone
PRIMARY BACKING 7.5 oz/yd2; TenCate K29 Backing (Double
Layer Thiobac, black, U.V. stabilized;
Layer 1: 100% PP, Layer 2: PET/PP blend)
SECONDARY BACKING 20 oz/yd2 Polyurethane coating with
drainage holes
TOTAL WEIGHT 83.5 oz/yd2
PILE HEIGHT 1 5/8 inch
FACE WEIGHT* 56 oz/yd2
MACHINE GAUGE 1/2 inch
SET UP 2 ends/needle, A/B (face fibers)
ROLL WIDTH 182 inch
WATER PERMEABILITY > 50 inches/hour
TUFT BIND (ASTM D1335) > 8 lbs
GRAB TEAR (ASTM D5034) 250/250 lbs
PILL FLAMMABILITY (ASTM D2859) Pass
-
BLEND OF MONOFILAMENT AND
SLIT FILM FIBERS WITH TEXTURIZED
MONOFILAMENT
STANDARD COLORS**
NAVY BLUE
Pantone: 282C
FLORIDA BLUE
Pantone: 281C
BROWN
Pantone: 1545C
GRAY
Pantone: 422+429
RED
Pantone: 185C
BLACK
Pantone: 000C
BLUE LAGOON
Pantone: 2925C
ORANGE
Pantone: 166C
RED CLAY
Pantone: 7526C
CRIMSON
Pantone: 202C
TAN
Pantone: 728C
BLUPLE
Pantone: 268C
BRIGHT YELLOW
Pantone: 136C
VEGAS GOLD
Pantone: 466C
WHITE
Pantone: 000
FIELD GREEN
Pantone: 575C
LIME GREEN***
Pantone: 7496C
FIELD GREEN/
LIME GREEN
WHEN USED WITH LIGHTWEIGHT INFILLS
No Infill. No Microplastics. No PFAS.
Pivottm by TenCate is a true game changer. Designed with
extensive feedback from top-level athletes, Pivottm by TenCate
provides ultimate performance, maximum player comfort and
ultra-durability.
The unique combination of yarns plays and responds like the best natural grass and
will perform at Year 10 like it does on Day 1. Additionally, Pivottm by TenCate is the
environmentally-friendly choice – no infill is needed and real-grass feel is achieved
without any resource intensive maintenance.
PIVOT BY TENCATE
TM
TURF
PILE CONTENT TenCate XP+ U.V. resistant slit film,
combined with TenCate semi-TXT
and TXT monofilament root zone.
PRIMARY BACKING 7.5 oz/yd2; TenCate K29 Backing (Double
Layer Thiobac, black, U.V. stabilized,
Layer 1: 100% PP, Layer 2: PET/PP blend)
SECONDARY BACKING 20 oz/yd2 Polyurethane coating with
drainage holes
TOTAL WEIGHT 117.5 oz/yd2
PILE HEIGHT 1 1/8 inch
FACE WEIGHT* 90 oz/yd2
MACHINE GAUGE 3/8 inch
SET UP 3 ends/needle
ROLL WIDTH 182 inch
WATER PERMEABILITY 64 inches/hour (unfilled)
TUFT BIND (ASTM D1335) > 9 lbs
GRAB TEAR (ASTM D5034) 274 lbs length, 395 lbs width
PILL FLAMMABILITY (ASTM D2859) Pass
-
TENCATE AMERICAS | 1131 BROADWAY ST. DAYTON, TN 37321 | (855) 773-6668 | TENCATEGRASS.COM | VERSION 202
BEST FOR SOFTBALL, BASEBALL
AND WARNING TRACKS.
YARN
DENSITY (DENIER) 5,040/1 (XP+);
5,400/6 (semi-TXT);
7,200/10 (TXT)
THICKNESS (MICRONS) 100 (XP+);
152 (semi-TXT);
145 (TXT)
MELTING POINT 128° C | 260° F
BREAKING STRENGTH 11 lbs/force (XP+);
20 lbs/force (semi-TXT);
20 lbs/force (TXT)
LEAD CONTENT (PPM) <100
BLEND OF DURABLE SLIT FILM AND
SEMI-TEXTURIZED AND TEXTURIZED
MONOFILAMENT FIBERS
Pile Height, Max Thickness, Face Weight, Primary & Secondary Backing, and Total Weight can differ by ±10%. The Stitch Rate will change according to the exact
specifications and can differ by ±1. Roll Width can differ by ±0.8 inch.
TenCate has the right to alter each product specification in order to improve the system according to the latest standards. TenCate is not legally liable in case of
noncompliance with the above mentioned specifications.
*Face Weight reflects entire length of yarn, including portion woven into backing, which is consistent with standard ASTM method of measuring tuft including back stitch.
PIVOT BY TENCATE 1.125" SPECSTM
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EDMUND G. BROWN JR., Attorney General
J. MATTHEW RODRIQUEZ, Chief Assistant Attorney General
KEN ALEX, Senior Assistant Attorney General
EDWARD G. WEIL, Supervising Deputy Attorney General
DENNIS A. RAGEN, Deputy Attorney General, Bar No. 106468
110 West A Street, Suite 1100
San Diego, California 92186-5266
Telephone: (619) 645-2016
Fax: (619) 645-2012
CARMEN A. TRUTANICH, Los Angeles City Attorney
EARL E. THOMAS, Chief of Criminal and Special Litigation
PATRICIA BILGIN, Assistant City Attorney, Environmental Justice Unit
ELISE RUDEN, Deputy City Attorney, Bar No. 124970
VAUGHN MINASSIAN, Deputy City Attorney, Bar No. 203574
200 North Main Street, 500 City Hall East
Los Angeles, California 90012-4131
Telephone: (213) 978-8080
Fax: (213) 978-8111
DAVID W. PAULSON, District Attorney of Solano County
CRISELDA B. GONZALEZ, State Bar No. 146493
Senior Deputy District Attorney
675 Texas Street, 4th Floor, Suite 4500
Fairfield CA 94533-6396
Telephone: (707) 784-6859
Fax: (707) 784-9001
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF ALAMEDA
PEOPLE OF THE STATE OF CALIFORNIA,
ex rel. EDMUND G. BROWN, JR., Attorney
General, CARMEN A. TRUTANICH, Los
Angeles City Attorney, DAVID W.
PAULSON, Solano County District Attorney
Plaintiff,
v.
BEAULIEU GROUP, LLC, et al.
Defendants
Case No. RG 08407310
CONSENT JUDGMENT AS TO
DEFENDANT ASTROTURF , LLC
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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1. INTRODUCTION
1.1 On September 2, 2008, the People of the State of California (“People” or
“Plaintiffs”), by and through the Attorney General of the State of California (“Attorney
General”), the Los Angeles City Attorney and the Solano County District Attorney, filed a
complaint for civil penalties and injunctive relief for violations of Proposition 65 and unlawful
business practices in the Superior Court for the County of Alameda. The People’s Complaint
alleges that the named Defendants failed to provide clear and reasonable warnings that their
artificial turf products (the “Products”) contain lead, and that use of, and contact with, those
Products results in exposure to lead, a chemical known to the State of California to cause cancer
and reproductive harm. The Complaint further alleges that under the Safe Drinking Water and
Toxic Enforcement Act of 1986, Health and Safety Code section 25249.6, also known as
“Proposition 65,” businesses must provide persons with a “clear and reasonable warning” before
exposing individuals to these chemicals, and that the Defendants failed to do so. The Complaint
also alleges that these acts constitute unlawful acts in violation of the Unfair Competition Law,
pursuant to Business and Professions Code sections 17200 et seq. and 17500 et seq.
1.2 AstroTurf, LLC , Crystal Products Co., Inc. d/b/a SYNLawn, UGTH Equipment,
LLC, General Sports Venue, LLC, and Synthetic Turf Resources, LLC (“Settling Defendants”)
are among the Defendants named in the complaint.
1.3 Settling Defendants are alleged to be interrelated corporations that, separately and
together, employ more than 10 persons and employed ten or more persons at all times relevant
to the allegations of the complaint.
1.4 Settling Defendants manufacture, license, distribute and/or sell Products in the
State of California and/or have done so in the past four years.
1.5 For purposes of this Consent Judgment only, the People and the Settling
Defendants stipulate that this Court has jurisdiction over the allegations of violations contained
in the People’s Complaint and personal jurisdiction over Settling Defendants as to the acts
alleged in the People’s Complaint, that venue is proper in Alameda County, and that this Court
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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has jurisdiction to enter this Consent Judgment as a full and final resolution of all claims which
were or could have been raised in the Complaint based on the facts alleged therein.
1.6 The People and Settling Defendants enter into this Consent Judgment as a full and
final settlement of all claims relating to Covered Products (as that term is defined below) arising
from the failure to warn regarding the presence of lead in such Products. By execution of this
Consent Judgment and agreeing to provide the relief and remedies specified herein, Settling
Defendants do not admit any violations of Proposition 65 or Business and Professions Code
sections 17200 et seq. or 17500, et seq. or any other law or legal duty. Except as expressly set
forth herein, nothing in this Consent Judgment shall prejudice, waive or impair any right,
remedy, or defense the People and Settling Defendants may respectively have in any other or in
future legal proceedings unrelated to these proceedings. However, this Paragraph shall not
diminish or otherwise affect the obligations, responsibilities, and duties of the parties under this
Consent Judgment, or the res judicata impacts of this Consent Judgment on other litigation
brought under Proposition 65 or the Business and Professions Code.
2. DEFINITIONS
2.1 The “Effective Date” of this Consent Judgment shall be the date on which the
Consent Judgment is entered as a judgment by the trial Court (“Effective Date”).
2.2 Covered Products shall mean (a) the products listed in Exhibit A to this Consent
Judgment and (b) any other artificial turf products that Settling Defendants may manufacture or
sell after the Effective Date.
2.3 “Cushioning Products” shall mean any foam layering or other products that are
installed under the Covered Products but are not attached to the Covered Products by the
manufacturer.
2.4 “Infill Products” shall mean any granular product, including, without limitation,
crumb, tire crumb, pellets, sand, or synthetic sand, that is installed under, on, or in connection
with any Covered Product.
2.5 “Old Covered Products” shall mean Covered Products that were Sold In California
before the Effective Date of this Judgment.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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2.6 “Sold in California” means any Covered Product that is sold in the State of
California by Settling Defendants or by any, distributor, wholesaler or retailer that is authorized
by Settling Defendants, to sell the Covered Products. For purposes of this Judgment, the date of
sale shall be the later of the following: (a) the date of the sales contract; (b) the date that Settling
Defendants transport or dispatch the Covered Product into California; (c) the date that Settling
Defendants deliver, or cause the delivery of, the Covered Product to the installation site.
3. INJUNCTIVE RELIEF: LEAD REDUCTION
3.1 Immediate Product Reformulation. Immediately upon the Effective Date of this
Consent Judgment, Settling Defendants shall reduce the level of lead in the Covered Products
Sold in California from the current levels to a level no higher than 100 parts per million
(“Compliance Level”) as determined pursuant to the testing protocol in Exhibit B.
3.2 Further reductions in lead levels in Covered Products. In addition to the
requirements of Paragraph 3.1, and effective June 15, 2010, the Covered Products shall meet the
following additional requirements (which shall be referred to as the “Further Compliance
Level”):
(a) No portion of the Covered Product may have lead levels in excess of 50
parts per million, except:
(b) Field lines and markings (such as yard lines, goal lines and team names or
logos) may not have lead levels in excess of 100 parts per million.
In the event that Settling Defendants’ Covered Products violate the Further Compliance Level,
Settling Defendants will (i) consult with their suppliers and technical consultants; (ii) attempt to
locate the source of the elevated lead seen the laboratory results; and (iii) provide the Plaintiffs
with a report on this investigation and a proposal to prevent the situation from occurring in the
future. On approval by the Attorney General, Settling Defendants will implement this proposal.
In the event that the Attorney General incurs laboratory costs in reviewing such a proposal,
Settling Defendants will reimburse the Attorney General for reasonable laboratory costs actually
incurred.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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4. INJUNCTIVE RELIEF: CLEAR AND REASONABLE WARNINGS
4.1 The People allege that warnings are necessary as to the Old Covered Products
because these products cause continuing exposures to lead. Without admitting such allegations,
Settling Defendants agree to implement the following program to provide clear and adequate
warnings to persons who come into contact with turf products that were installed before the
Effective Date of this Judgment.
(a) Settling Defendants shall provide the mailed warnings and informational
materials attached hereto as Exhibit C, in English and Spanish, to all parties who
purchased Old Covered Products for installation within the State of California on or after
April 1, 2004 for Astro branded products and November 1, 2006 for the remaining
Covered Products. Settling Defendants will send these mailed warnings within thirty days
after receiving instructions to do so from the Attorney General.
(b) Beginning thirty days after the Effective Date, and for a period of two years
thereafter, Settling Defendants will establish a web site that complies with the provisions
of Exhibit C, which shall provide the following information, in English and Spanish, about
its products:
• Range of lead content for each Covered Product
• The date lead was phased out of each Covered Product
• A warning informing consumers that the products in question contain lead, which
is a chemical known to the State of California to cause cancer and reproductive
harm.
• Proposition 65 and other regulatory levels applicable to lead in consumer products.
• Links to specified sites
• Good maintenance practices to minimize lead transfer from Covered Products to
consumers.
• Actions consumers can take to minimize lead transfer from Covered Products to
consumers.
• Options for Lead Transfer Testing of Covered Products.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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The initial design and content of the website, and any later changes to the website
will be subject to the advance approval of Plaintiffs, which shall not be
unreasonably withheld.
If a trade association, a group of turf companies, or other responsible entities create
a web site that is approved by Plaintiffs and satisfies the provisions of this
Paragraph 4.1(b), Settling Defendants may comply with the terms of this Paragraph
by placing a conspicuous link to that website on the websites maintained by
AstroTurf and SYNLawn.
5. ADDITIONAL ACTIONS BY SETTLING DEFENDANTS
5.1 Plaintiffs have agreed to accept the settlement payment set forth in Section 5.2 -
5.4 below (Civil Penalties, Cy Pres, Other Payments) based on Settling Defendants’
commitment to take additional actions. Specifically, Settling Defendants shall do the following:
(1) Replacing Certain Old Covered Products. Settling Defendants shall
replace any Old Covered Products in place as of the Effective Date and installed in
the State of California after April 1, 2004 for Astro branded products and
November 1, 2006 for the remaining Covered Products, if
i. The Old Covered Product was (i) installed at a licensed day
care facility, a school, a public playground, or a public playing field
and (ii) has been in place for more than 3 years but not more than 8
years.
ii. the Lead Transfer Testing conducted pursuant to Exhibit D
shows Available Lead Levels in excess of 0.1 micrograms per
square centimeter;
iii. The owner or operator of the day care center, school,
playground or playing field makes written request to AstroTurf that
the field be replaced, and this request is received by AstroTurf no
later than February 1, 2012. Settling Defendants shall not be
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required to honor any requests for replacement of Old Covered
Product that are received after that date.
iv. The owner or operator shows proof of purchase and delivery
of the Covered Product to the location at issue.
(2) Maximum Expenditure. Settling Defendants shall not be required to
provide more than 20,000 square yards of turf in order to comply with the
provisions of this Section 5.1(1). Settling Defendants will monitor the number of
qualifying requests for replacement, and if it appears that this quantity of turf will
prove insufficient to achieve full compliance with those terms, Settling Defendants
shall, after receiving written approval and direction from Plaintiffs, pro-rate the
remaining funds among the remaining claimants.
(3) Quality. The quality of the replacement turf that Settling
Defendants provide pursuant to this section will be comparable to, or better than,
the turf that is being replaced.
5.2 Civil Penalties. On or before June 1, 2010, Settling Defendants shall pay a civil
penalty of $ 17,500 pursuant to California Health & Safety Code §§ 25249.7(b) and 25249.12.
Pursuant to section 25249.12, 75% of these funds shall be remitted to the California Office of
Environmental Health Hazard Assessment (“OEHHA”), and the remaining 25% apportioned
evenly among the Attorney General, the Los Angeles City Attorney, and the Solano County
District Attorney.
5.3 Cy Pres. Settling Defendants shall make the following payments in lieu of
penalties:
(a) Settling Defendants shall pay $ 60,000 to the California Public Health
Trust. $40,000 shall be paid within 30 days of the Effective Date and $20,000 shall be paid on or
before February 15, 2010. These funds shall be used, as the Trust directs after conferring with
Plaintiffs, for some or all of the following:
(1) To fund independent testing, which shall be conducted pursuant to
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the protocol attached as Exhibit D (Lead Transfer Testing), of Old Covered
Products currently installed and in place at licensed day care centers, schools, and
public playing fields in California; and to fund efforts to promote consistent testing
of Old Covered Products throughout California.
(2) For research into Good Maintenance Practices, including the
feasibility of applying stabilizers to Old Covered Products in order minimize lead
transfer from those products.
(3) To provide funding for an independent consultant, who will provide
information to schools, municipalities and other locations in California where Old
Covered Products are installed, regarding independent testing and Good
Maintenance Practices for such products.
(4) For other projects or grants for the purposes of reducing, or
educating the public about, lead in consumer products.
(5) Any process undertaken by the Public Health Trust to identify and
choose the entity(ies) that will receive any grant to be awarded under this Judgment
must be open to public scrutiny and subject to public notice and comment. Any
use of funds must be approved by the Attorney General.
(6) In order to minimize any duplication of effort, the Public Health
Trust will coordinate the expenditure of funds received pursuant to this Judgment
with any expenditures made pursuant to (i) judgments with other defendants in this
case and (ii) judgments in other cases in which the Attorney General has alleged
that lead in present in consumer products.
(b) On or before October 1, 2009, Settling Defendants shall pay $30,000 to the
Office of Environmental Health Hazard Assessment (OEHHA), to be deposited into
OEHHA’ Proposition 65 Fund, to be used, on appropriation of the Legislature, to fund to
fund a study or studies relating to potentially hazardous chemicals in Infill Products.
OEHHA shall coordinate these studies with studies that it may conduct pursuant to SB
1277 (Maldonado).
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5.4 Other Payments. Settling Defendants shall also make the following payments:
(a) Attorney General. On or before June 1, 2010, Defendant shall pay the sum
of $17,500 to the Attorney General, to reimburse the fees and costs his office has expended with
respect to this matter. Funds paid pursuant to this paragraph shall be placed in an interest-bearing
Special Deposit Fund established by the Attorney General. These funds, including any interest,
shall be used by the Attorney General, until all funds are exhausted, for the costs and expenses
associated with the enforcement and implementation of Proposition 65, including investigations,
enforcement actions, other litigation or activities as determined by the Attorney General to be
reasonably necessary to carry out his duties and authority under Proposition 65. Such funding may
be used for the costs of the Attorney General’s investigation, filing fees and other court costs,
payment to expert witnesses and technical consultants, purchase of equipment, travel, purchase of
written materials, laboratory testing, sample collection, or any other cost associated with the
Attorney General’s duties or authority under Proposition 65. Funding placed in the Special
Deposit Fund pursuant to this paragraph, and any interest derived therefrom, shall solely and
exclusively augment the budget of the Attorney General’s Office and in no manner shall supplant
or cause any reduction of any portion of the Attorney General’s budget.
(b) City Attorney and Solano County District Attorney. On or before June 1,
2010, Settling Defendants shall make payments of $ 10,000 to the Los Angeles City Attorney and
$ 10,000 to the Solano County District Attorney to defray the attorneys’ fees and costs these
offices have expended with respect to this matter.
(c) Center for Environmental Health/Other Private Parties. Within thirty days
of the Effective Date, and pursuant to Health & Safety Code section 25249.7(j), Settling
Defendants shall pay $25,000 to the Center for Environmental Health and Lexington Law Group.
These payments represent full compensation from the Settling Defendants for (i) the assistance
that CEH has provided to the Plaintiffs and (ii) the fees and costs that CEH has incurred with
respect to this matter.
5.5 Each payment required by this Consent Judgment shall be made through the
delivery of separate checks payable to the applicable person, as follows:
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(a) Attorney General. Payments due to the Attorney General shall be made
payable to the “California Department of Justice,” and sent to the attention of Robert Thomas,
Legal Analyst, Department of Justice, 1515 Clay Street, 20th Floor, Oakland, CA 94612.
(b) City Attorney. Payments due to the City Attorney shall be made payable to
the “Office of the Los Angeles City Attorney” and sent to: Patty Bilgin, Supervising Attorney,
Environmental Justice Unit, Office of the Los Angeles City Attorney 200 North Main Street, 500
City Hall East, Los Angeles, California 90012-4131
(c) Solano County District Attorney. Payments due to the Solano County
District Attorney shall be made payable to the “Office of the Solano County District Attorney”
and sent to Criselda B. Gonzalez, Senior Deputy District Attorney, Office of the Solano County
District Attorney, 675 Texas Street, 4th Floor, Suite 4500, Fairfield CA 94533-6396.
(d) Office of Environmental Health Hazard Assessment. Payments due to the
OEHHA shall be made payable to the Office of Environmental Health Hazard Assessment and
sent to: Beverly Sloan, Senior Accounting Officer, Office of Environmental Health Hazard
Assessment, P.O. Box 4010, Sacramento, CA 95812-0410.
(e) Center for Environmental Health/Lexington Law Group. The payment due
to the Center for Environmental Health shall be made payable to the Lexington Law Group and
sent to: Mark N. Todzo, Lexington Law Group, LLP, 1627 Irving Street, San Francisco, CA
94122
(f) Copies of checks. Settling Defendants will cause copies of each and every
check issued pursuant to this Judgment to be sent to: Dennis A. Ragen, Deputy Attorney General,
110 West A. Street, Suite 1100, San Diego, California 92101
(g) Late Payment/Acceleration. If any payment required by Sections 5.2, 5.3
or 5.4 of this Judgment is not received by the due date, then Plaintiffs will provide Settling
Defendants ten (10) days’ notice of default. If Settling Defendants fails to cure the default within
said ten (10) days, then at the option of the Attorney General, all unpaid balances due pursuant to
those sections shall be accelerated, and shall become immediately due and payable, with interest
thereon as specified in section 685.010 of the Code of Civil Procedure, commencing to accrue 10
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on the entire remaining unpaid balance of any sum pursuant those sections, as of the first day
immediately after the ten-day delinquency that preceded the notice of default. Code of Civil
Procedure section 1013, and the extensions provided for therein, shall not apply to nor extend any
deadline referred to in this paragraph or in Sections 5.2, 5.3 and 5.4 of this Judgment. If the
Attorney General declines to exercise and waives this optional acceleration as to any one or more
default(s) in payment, said waiver or waivers shall not constitute a waiver of this option in the
event of any other default. Defendants are permitted at their option to pre-pay any time the
remaining unpaid balance of any amount due in this judgment.
6. MODIFICATION OF CONSENT JUDGMENT
6.1 This Consent Judgment may be modified from time to time by express written
agreement of the Parties with the approval of the Court; by an order of this Court on noticed
motion from Plaintiffs or Defendant in accordance with law, for good cause shown; or by the
Court in accordance with its inherent authority to modify its own judgments.
6.2 Before filing an application with the Court for a modification to this Consent
Judgment, the party seeking modification shall meet and confer with the other party to
determine whether the modification may be achieved by consent. If a proposed modification is
agreed upon, then Settling Defendants and the Attorney General will present the modification to
the Court by means of a stipulated modification to the Consent Judgment.
7. ENFORCEMENT
7.1 Plaintiffs may, by motion or application for an order to show cause before this
Court, enforce the terms and conditions contained in this Consent Judgment. In any such
proceeding, Plaintiffs may seek whatever fines, costs, penalties, or remedies are provided by law
for failure to comply with the Consent Judgment and where said violations of this Consent
Judgment constitute subsequent violations of Proposition 65 or other laws independent of the
Consent Judgment and/or those alleged in the Complaint, the Plaintiffs are not limited to
enforcement of the Consent Judgment, but may seek in another action whatever fines, costs,
penalties, or remedies are provided for by law for failure to comply with Proposition 65 or other
laws. In any action brought by Plaintiffs or another enforcer alleging subsequent violations of
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Proposition 65 or other laws, Settling Defendants may assert any and all defenses that are
available, including the res judicata or collateral estoppel effect of this Consent Judgment.
8. AUTHORITY TO STIPULATE TO CONSENT JUDGMENT
8.1 Each signatory to this Consent Judgment certifies that he or she is fully authorized
by the party he or she represents to stipulate to this Consent Judgment and to enter into and
execute the Consent Judgment on behalf of the party represented and legally to bind that party.
9. CLAIMS COVERED
9.1 Full and Binding Resolution. This Consent Judgment is a full, final, and binding
resolution between the People and Settling Defendants, of any violation of Proposition 65.,
Business & Professions Code sections 17200 et seq. and 17500, et seq. or any other statutory or
common law claims that have been or could have been asserted in the Complaint against
Settling Defendants for failure to provide clear and reasonable warnings of exposure to lead
from the use of the Covered Products, or any other claim based on the facts or conduct alleged
in the Complaint, whether based on actions committed by Settling Defendants or by any entity
to whom Settling Defendants distribute or sells Covered Products, or any entity that sells the
Covered Products to consumers. Compliance with the terms of this Consent Judgment resolves
any issue now, in the past, and in the future, concerning compliance by any Settling Defendant,
its parents, shareholders, divisions, subdivisions, subsidiaries, sister companies, affiliates,
franchisees, cooperative members, and licensees; its distributors, wholesalers, and retailers who
sell Covered Products; and the predecessors, successors, and assigns of any of them, with the
requirements of Proposition 65 or Business and Professions Code sections 17200 et seq. and
17500 et seq. arising from exposures to lead in or from the Covered Products. This Consent
Judgment does not resolve any claims that Plaintiffs may assert with respect to (i) products other
than the Covered Products, or (ii) chemicals other than lead.
9.2 Covered Entities. Settling Defendants unconditionally guarantee that each other
Settling Defendant will fully comply with the applicable provisions of this Consent Judgment,
including the provisions of Sections 3 (Injunctive Relief: Lead Reduction) and 4 (Injunctive
Relief: Clear and Reasonable Warnings), and the applicable provisions of Section 5
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(Additional Actions by Settling Defendants). If any such company fails to so comply with the
applicable provisions of this Consent Judgment, then in addition to Plaintiffs’ other remedies,
Plaintiffs reserve the right to bring action, seeking penalties, injunctive and other relief, directly
against such company to redress that company’s non-compliance.
9.3 Further Reservations: Without limiting the rights reserved to Plaintiffs in the
preceding paragraphs, Plaintiffs also reserve the right to bring actions, seeking penalties,
injunctive and other relief, against the following persons:
(a) Downstream Sellers. Distributors, wholesalers, and/or retailers who, after
the Effective Date of this Judgment: (i) sell Covered Products that contain lead levels in
excess of the applicable levels set forth in Secton 2.1 of this Judgment (Injunctive Relief:
Lead Reduction), or (ii) otherwise fail to comply with, or impede the efforts of others to
comply with, the applicable terms of this Consent Judgment; and
(b) Undisclosed Affiliates. Any affiliate or subsidiary of Settling Defendants
that is not bound by the terms of this Consent Judgment.
(c) Not Applicable to Cushioning and Infill Products. This Consent Judgment
does not apply to any Cushioning Products or Infill Products. Plaintiffs expressly reserve
the right to bring claims against Settling Defendants or any distributors, wholesalers, or
retailers of Cushioning Products or Infill Products, for any violation of Proposition 65, the
Unfair Competition Law or any other applicable law or regulation, arising from the sale,
use of, or exposure to any Cushioning Products or Infill Products.
10. ONGOING INVESTIGATION
10.1 Plaintiffs are conducting an ongoing investigation of lead and other chemicals in
artificial turf and related products sold by companies other than Settling Defendants. In
connection with this investigation, Settling Defendants will, upon reasonable notice, provide
plaintiff with information, product samples, and other information and materials within their
possession, custody or control, or that are readily available to them, relevant to such
investigation, except to the extent that such information is privileged or otherwise protected
from disclosure.
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11. PROVISION OF NOTICE
11.1 When any party is entitled to receive any notice under this Consent Judgment, the
notice shall be sent to the person and address set forth in this Paragraph. Any party may modify
the person and address to whom the notice is to be sent by sending each other party notice by
certified mail, return receipt requested. Said change shall take effect for any notice mailed at
least five days after the date the return receipt is signed by the party receiving the change.
11.2 Notices shall be sent by e-mail and by First Class Mail or overnight delivery to the
following when required:
For the Attorney General:
Dennis A. Ragen, Deputy Attorney General
California Department of Justice
110 West A. Street, Suite 1100
San Diego, CA 92101
Dennis.Ragen@doj.ca.gov
and simultaneously to:
Robert Thomas, Legal Analyst,
Department of Justice,
1515 Clay Street, 20th Floor,
Oakland, CA 94612
Robert.Thomas@doj.ca.gov
For the Los Angeles City Attorney
Patty Bilgin, Supervising Attorney, Environmental Justice Unit
Office of the Los Angeles City Attorney
200 North Main Street, 500 City Hall East
Los Angeles, California 90012-4131
Patty.Bilgin@lacity.org
For the Solano County District Attorney
Criselda B. Gonzalez
Senior Deputy District Attorney
Office of the Solano County District Attorney
675 Texas Street, 4th Floor, Suite 4500
Fairfield CA 94533-6396
CGonzalez@SolanoCounty.com
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For the Center for Environmental Health
Mark N. Todzo
Lexington Law Group, LLP
1627 Irving Street
San Francisco, CA 94122
mtodzo@lexlawgroup.com
11.3 Notices for the Settling Defendants shall be sent to:
Joann Brown Williams
General Counsel
2680 Lakeland Road
Dalton, Georgia 30721
(706) 876-5556
jwilliams@textilemanagement.com
11.4 Written Certification. Within 15 days of any completing any action required by
this Consent Judgment, and also on Plaintiffs’ written request, Settling Defendants will provide
Plaintiffs with written certification that the required action has been completed.
12. COURT APPROVAL
12.1 This Consent Judgment shall be submitted to the Court for entry by noticed motion
or as otherwise may be required or permitted by the Court. If this Consent Judgment is not
approved by the Court, it shall be of no force or effect and may not be used by the Plaintiffs or
Settling Defendants for any purpose.
13. ENTIRE AGREEMENT
13.1 This Consent Judgment contains the sole and entire agreement and understanding
of the Parties with respect to the entire subject matter hereof, and any and all prior discussions,
negotiations, commitments and understandings related hereto. No representations, oral or
otherwise, express or implied, other than those contained herein have been made by any Party
hereto. No other agreements not specifically referred to herein, oral or otherwise, shall be
deemed to exist or to bind any of the Parties.
14. RETENTION OF JURISDICTION
14.1 This Court shall retain jurisdiction of this matter to implement and enforce the
Consent Judgment, and to resolve any disputes that may arise as to the implementation of this
Judgment.
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15,
15.! stij:Jul,atil)!1S to ex(;cuted in cOLmt(;rp:~lrlS by
Incan$ be do(;m(:;d to cO.nstitute ono (/O(;Urnerll.
fl" IS
/\Ugllst.!.~.,
DAVID \V.
District .Atlt:Orlley·
16
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15. EXECUTION IN COUNTERPARTS
15.1 The stipulations to this Consent Judgment may be executed in counterparts and by
means of facsimile, which taken together shall be deemed to constitute one document.
IT 1S SO ORDERED and ADJUDGED:
DATED: _
JUDGE OF THE SUPERIOR COURT
IT IS SO ST1PULATED:
DATED: August_, 2009 EDMUND G. BROWN, JR.
Attorney General
J. MATTHEW RODRIQUEZ
Chief Assistant Attorney General
KEN ALEX
Senior Assistant Attorney General
EDWARD G. WElL
Supervising Deputy Attorney General
DATED: August_, 2009
DATED: August /3,2009 DAVID W. PAULSON,
District Attorney of Solano County
BY:C~:;.·G~Jf"-=------
Deputy District Attorney
By:
=D-=E::-:NN::-::::IS,-A:-.-=RA:-:-:G=E=-N:---------
Deputy Attorney General
For Plaintiffs People of the State of California
CARMEN A. TRUTANICH
Los Angeles City Attorney
EARL E. THOMAS,
Chief of Criminal and Special Litigation
ELISE A. RUDEN
Deputy City Attorney
VAUGHN MINASSIAN
Deputy City Attorney
By:
=PA:-TT=yc:-=B=IL--:G=IN:-:---------
Assistant City Attorney,
Environmental Justice Unit
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DATED: August 1::', 2009 ASTR0=::u.
By: zq.
Its: +>R-es:tk,t
DATED: August 13, 2009 CRYSTAL PRODUCTS CO., INC.
d/b/a SYNLAWNBy:q-Q<=
Its: ?ft<::Scd(Qt _
DATED: August 13,2009 UGTHEQUlP~C
By: . ~0\t\~~
Its: ill ,M ~£I'Z,
DATED: August J2, 2009 SYNTHETIC TUR.(RrSOURC.ES, LLC
. By: 0dM .Y'"ll ff .
Its: p'u,:.j dfvJt . ..
DATED: August \.3,2009
By: -b""£-~~~~....."..---,..-
Its:
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF -Case No. RG 08407310
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Exhibit A
Covered Products
A 1 – AstroTurf Styles sold into California
A 2 - Crystal Styles sold into California
A 3 - SYNLawn Styles sold into California
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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AstroTurf Styles Sold Into California
5/2004 ‐7/2009
4212 P0001
A0001 P3038
A5513 PB03
AT38 PF01
BCB10 PG32
BL10 RP02
CC2 RP04
DB40 RP07
E120T RTT01
E200 SD01
E360 SPG1
E500 SPG2
E610H SR01
E620H SR21
E640H ST65
E740 TELN
E750 TMINV
E840H TPN
E840T WG1
E955H WG2
ET100
FSF3
G130
G220
G2625
G3225
G4019
GC42
GDXPE
GM48
GXD32
LAN43
LL1
LS01
LS05
LS06
LS21
LSX3
LX60
MG1
MG2
MG3
NGC42
NGC52 Exhibit A‐1
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Crystal Styles Sold Into California
2000 ‐2009
Bermuda I E820
Bermuda II E830
C1000 E840
C2000 E955H
C3000 FSF3
C4000 G110
C5000 G120
Concepts G130
Designer Choice G410
Duro Turf G430
Heather Point G450
Legend GM48
Leisure Turf LS01
Marine Carpet LS02
Master Turf LS03
Natural Weave LS21
Palace Gates LS31
Precepts LSX1
ST18 LSX2
ST24 LSX3
ST48 PE40
Turflawn PE50
ST35 PF01
PS100
AT26 PS400
AT38 PS700
E100 RP01
E200 RP02
E300 RP03
E355 RP04
E360 RP06
E400 RP07
E500 SPFT
E550 SW38
E610 TL100
E620 TL120
E630 TL80
E640 TP28
E710 TP38
E730 TP40
E740 TP41
E750 TP42
E800 TP50
E810 Exhibit A‐2 20
SYNLawn Styles Sold Into California
11/2006 ‐7/2009
BG28 basix by synlawn 28
BG30 basix by synlawn 30
BL10 basix by synlawn 10
BL100 basix by synlawn 100
BL20 basix by synlawn 20
BL30 basix by synlawn 30
BL40 basix by synlawn 40
BL60 basix by synlawn 60
BL70 basix by synlawn 70
BL80 basix by synlawn 80
SA100 SYNAugustine 100
SA130 SYNAugustine 130
SA140 SYNAugustine 140
SA230 SYNAugustine 230
SA240 SYNAugustine 240
SA330 SYNAugustine 330
SA340 SYNAugustine 340
SB100 SYNBlue 100
SB200 SYNBlue 200
SC100 SYNFringe 100
SC200 SYNFringe 200
SC210 SYNFringe 210
SD200 SYNBermuda 200
SD210 SYNBermuda 210
SD300 SYNBermuda 300
SD310 SYNBermuda 310
SF100 SYNFescue 100
SF110 SYNFescue 110
SF120 SYNFescue 120
SF214 SYNFesuce 214
SF220 SYNFescue 220
SF222 SYNFescue 222
SF310 SYNFescue 310
SF320 SYNFescue 320
SF340 SYNFescue 340
SF355 SYNFescue 355
SG100 SYNGreen 100
SG110 SYNGreen 110
SG134 SYNGreen 134
SG138 SYNGreen 138
SG150 SYNGreen 150
SG200 SYNGreen 200
SG300 SYNGreen 300
SG320 SYNGreen 320
SG322 SYNGreen 322
SG324 SYNGreen 324
SM110 SYNMarathon 110
SM112 SYNMarathon 112
SM114 SYNMarathon 114
SM120 SYNMarathon 120
SM130 SYNMarathon 130
SM210 SYNMarathon 210
SM220 SYNMarathon 220
SM222 SYNMarathon 222
SM230 SYNMarthon 230
SM240 SYNMarathon 240
SM310 SYNMarathon 310
SM312 SYNMarathon 312
SM320 SYNMarathon 320
SM330 SYNMarathon 330
SM355 SYNMarathon 355
SP300 SYNPlay 300
SP320 SYNPlay 320
SR100 SYNRye 100
SR200 SYNRye 200
SS300 SYNSod 300
ST100 SYNTipede 100
ST110 SYNTipede 110
ST120 SYNTipede 120
ST200 SYNTipede 200
ST220 SYNTIpede 220
ST320 SYNTipede 320
Exhibit A‐3
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Exhibit B
Testing Protocol for Use in Determining Lead Levels
1. Testing Protocol for Use in Determining Available Lead in Wipe Samples.
Each wipe will be prepared for analysis by acid digestion in accordance
with EPA Method 3050B. The digestate will be analyzed using ICP
spectrometry in accordance with EPA Method 6010c or alternatively EPA
Method 6020A.
2. Testing of Turf:
If turf is tested pursuant to Section 3.1 of this judgment, sample
preparation and analysis will be in accordance with EPA Method 3050B. The digestate
will be analyzed using ICP spectrometry in accordance with EPA Method 6010c or
alternatively EPA Method 6020A.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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Exhibit C
Dear Customer:
Our records show that you purchased [AstroTurf, SYNLawn] products during the past __
years. This letter is written to inform you that certain [AstroTurf, SYNLawn] products contain
lead. Specifically, the following Astroturf products contained lead at levels in excess of 100 parts
per million (ppm):
[List Products]
WARNING – The artificial turf products listed above contain lead, which is a chemical
known to the state of California to cause cancer and reproductive harm.
Lead was phased out of these products on the following dates:
Product Date
[Insert Product Name and Dates]
The following products have never contained lead in excess of 100 ppm.
[Insert Product Names]
Good maintenance practices can reduce exposures to lead from these products. These
practices include the following:
a. Keeping turf fields well-maintained and groomed and reducing surface dust and
particles that could be ingested
b. Students and players should wash their hands after playing on a field.
c. Food, beverages and other ingestible items should not be allowed on the field
d. Equipment and clothing used when playing on the turf should be cleaned after use.
For other information about this issue, please check the following links:
A program for testing exposures from turf products that are installed at day care facilities,
schools, public playgrounds, and public playing fields is now being administered by [Text to be
provided by Attorney General]. In order to participate in program, please contact:
[Text and further detail as to the program to be provided by the Attorney General.]
[Settling Defendants will consult with the Attorney General prior to finalizing the inserts to this
letter.]
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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Exhibit D
Lead Transfer Testing
Lead Transfer Testing shall be conducted as follows:
Materials
The materials used for sampling shall be lead free
1. Wipes
Premoistened GhostWipestm 15x15 cm
2. Delineations of area to be sampled
A cleanable template composed of thin plastic or metal, with inner dimensions of
the 10x50 cm rectangular area to be wiped.
Alternatively, masking tape and measuring tape will be used to delineate the
10x50 rectangular area to be wiped. The distance between the perimeter of the
inner and outer rectangles of the template or masking tape should be at least 5
cm.
4. Gloves
Disposable; plastic or rubber.
5. Sealable plastic bags, marker pen
Sampling Locations
Divide the total artificial turf area into 5 contiguous sections of equal areas.
This can be done by calculating the total area, dividing by 5 to determine the area
of each sampling location and then marking off the area to be sampled.
Three sampling locations should be in the center of their respectively
marked sections. Two sampling locations should be near the perimeter of the field
in their respectively marked sections.
Illustrations with various geometries are given in Attachment D-1.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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Plastic weights, chalk or string can be used to mark sample area
boundaries. A measuring wheel, chain, laser tape rule, or conventional tape rule
may be helpful, especially with complex geometries that might be found in a
landscape application.
Sampling
For each field set of samples, there will be a total of 7 bags: five bags with
one wipe in each bag, plus two bags with one blank wipe each.
1. Locate and delineate the areas to be wiped.
2. Wearing a new pair of gloves, remove a new wipe from its packaging and
unfold it to its full dimensions.
3. A total of 5 strokes are made over the 10x50 cm area.
Firmly and evenly press across the width of the wipe during sampling.
Each stroke will start at one end and proceed to the other end of the 50 cm
length.
Wipe with 2 linear strokes over the 50 cm length of the delineated area in
the same direction.
Fold the wipe with the exposed side in, orient the wipe with the 15 cm
crease at the leading edge, and wipe with 3 linear strokes over the 50 cm
length of the delineated area in the other direction.
4. Refold the wipe with the exposed sides in to form a square, and place it in a
new plastic bag. Seal and label the bag.
5. Discard the gloves. Clean the template if one was used. Discard the
masking tape, if used.
6. For each field set of samples, the sampling method blanks shall consist of
two unused wipes with packaging removed, each in an individual bag. If
the amount of Pb in a blank wipe does not reasonably closely match its
paired mate, or if both blank wipes are above an expected background
level, the sampling for that field set must be redone on areas not previously
wiped.
Lab Analysis
Lab Analysis will conducted according to Exhibit B - 1
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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Calculations
Assuming the results for the two blank wipes for the field set meet the conditions
in Sampling 6, average the two results.
The lead per square centimeter per stroke for each section of a field is
represented by
(ug lead on a wipe - average ug lead on the blank wipes for that field set) /
(500cm2 * 5 strokes) = ug lead /cm2 /stroke
The average (mean) for the field of artificial turf is the sum of the ug lead /cm2 /
stroke result for each of the 5 sections, divided by 5.
Consultation
The contractor selected to perform Lead Transfer Testing pursuant to this
Judgment may provide additional written instructions to the personnel who will be
conducting the Lead Transfer Testing. This contractor shall meet and confer with
representatives selected by Plaintiffs and Settling Defendant prior to initiating the
first round of testing.
The resulting lead levels shall be deemed to be the Available Lead Level pursuant to this
Judgment. These procedures and methods are meant only for use in this Judgment as a
method of determining when removal of an existing field is appropriate. They have not
been approved by the Plaintiffs or Settling Defendants as appropriate for making
exposure calculations or estimates pursuant to Health and Safety Code section 25249.6
et seq. or any other law or regulation.
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF – Case No. RG 08407310
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ExhibitD
Attachment D-l
CONSENT JUDGMENT AS TO DEFENDANT ASTROTURF -Case No. RG 08407310 -August 11, 2009
27
From:Leanne McAuliffe
To:Council, City
Subject:Meeting Nov 17, Action Item 9: Approval of the Study and Assessment of Turf Systems - Public Comment with
addition
Date:Friday, November 14, 2025 2:40:44 PM
Attachments:TTT pg1.png
TTT pg 2.png
TTT pg 3.png
TTT pg 4.png
TTT pg 5.png
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
i
Dear City Council Members,
For clarity, the below email sent on Nov 12 is a public comment is for the PA City Council
meeting on November 17, Action Item 9.
And a follow on note to that email:
The referenced Industry Tactics page mentions Gradient and it's worth noting that appendix E of the turf study
shows that Field Turf is using the firm Gradient to defend itself to the City of Palo Alto and that The Center for Public
Integrity describes Gradient as belonging to "a breed of scientific consulting firms that defends the products of its
corporate clients beyond credulity, even exhaustively studied substances whose dangers are not in doubt, such as
asbestos, lead and arsenic." The scientists who defend these products have been dubbed "rented white coats."
https://publicintegrity.org/environment/meet-the-rented-white-coats-who-defend-toxic-chemicals/
Sent: 12 November 2025 19:41
To: city.council@PaloAlto.gov <city.council@PaloAlto.gov>
Subject: Action Item 9: Approval of the Study and Assessment of Turf Systems -
Dear Palo Alto City Council Members,
Please take a few minutes to read the information in the link below regarding Industry Tactics
(Test the Turf Collaborative, 2025). This should help you understand the sheer frustration of
community members trying to educate and advocate for natural grass fields.
Community members are desperate to get good sports fields for our kids and many have
This message needs your attention
This is a personal email address.
Mark Safe Report
shared a plethora of information as to why natural turf is a holistically safer option than plastic
turf. (Safer for the health of kids, the environment and public funds.)
Since El Camino is already plastic, is the horse already out of the barn? Yes. But that doesn't
mean the decision can't be made to revert fields back to natural turf (which can take
substantially less than 18 months!) and stop any further damage.
Over the past 5 years of following and researching the topic of artificial turf I have seen
industry narrative morph from 1st Dog Defense (no harm) to 2nd Dog Defense (no risk) to
3rd Dog Defense (low risk) within our county, state and nationally. I then came to the
unfortunate realization that grass advocates and independent experts have in fact done the
plastic turf industry a huge favour because we have shared so much well researched,
documented and referenced information with decision makers (like you) that if industry has to
play the 4th Dog Defense (you knew) card then no one supporting or approving the installation
of plastic turf will be able to say they didn't know the risks. So can we please just stop the
madness now BEFORE industry needs to play the 4th Dog Defense card.
Don't approve the report in its current form.
Take the time to understand and acknowledge the risks of plastic fields as documented
by independent experts and have these incorporated into the report.
Consult independent Certified Sports Field Managers experienced in well designed,
installed and organically managed natural turf sports fields and have this information
incorporated into the report.
Approve conversion from plastic sports fields back to natural turf.
Take the multiple millions that would have gone into plastic fields and instead invest it
in properly maintaining natural turf fields. (Invest in our kids health, local jobs, and the
environment and not the profit driven multibillion dollar plastic industry.)
We can't change the beginning, but we can stop where we are and change the ending.
Kind regards,
Leanne McAuliffe
Santa Clara County resident
https://www.testtheturf.org/industry-tactics.html
NB: In the event that the link doesn't work I've attached screen shots of this web page. (labled
TTT pages 1-5)
From:Andrea Wald
To:Council, City
Subject:Mtg. 11/17/25 - Agenda item #9: Approval of the Study and Assessment of Turf Systems
Date:Thursday, November 13, 2025 3:21:51 PM
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i
Dear Mayor and Council members,
There has already been a great deal of material provided to you that talks about the inconsistencies
in the Lloyd Study and recommendations not to accept it. There has also been well
researched/documented materials provided that highlight the harms of artificial turf and why it
should not be installed in any of your city’s parks/athletic fields, residences, etc.
I’ve decided to take a different approach in my message today.
Are you aware of the 50 years it took concerned individuals to get action regarding cigarettes
because they were worried about the exposure to the harmful smoke – warnings on packaging, bans
to smoke in restaurants, office buildings, airports and on airplanes? Creating stricter rules for
vendors of cigarettes about verifying the age of the individual purchasing cigarettes – since there has
never been a law to simply outright ban them.
Well, the reason it took so long is because of the influence and associated wealth of the tobacco
industry and their paid lobbyists. Those asked to look into regulations were unduly influenced by
outsiders and did not take seriously enough all the harms of cigarette smoke – not only on those
who choose to smoke but the general public that was exposed to the toxins – and not by their own
choice.
Something extremely similar is happening with plastics in general – although for the purpose of my
urgent plea – I’m talking about synthetic ground coverings: artificial turf and PIP – poured-in-place
rubber. The manufacturers and vendors, the companies that are benefiting financially from a
product that does not last and must be replaced, that has no regulations in place for monitoring it
nor requirements to divulge the chemicals used in the manufacture process, no responsibility or
accountability for what happens to it when it comes to its useful end of life are all trying to convince
us of the safety of their product – and too many are believing them. What happened to common
sense and thinking that if there is any shred of doubt about the safety of a product that it should be
avoided?
As elected officials it is your responsibility to protect those in your community and even beyond,
since the impacts of unnecessary plastics, like artificial turf and PIP, do go beyond your city
boundaries. Should all community members be expected to bear the burden of the toxins and
microplastics associated with the artificial surfaces I’ve mentioned? And what about our youth?
People do continue to smoke but for most of us, that means they are affecting only their own health
– although we all bear the cost of expensive treatments for those who do come down with
debilitating illnesses related to their smoking. As for artificial turf and PIP – our youth do not have a
say in the toxins and microplastics we are exposing them to – with cumulative effects over years and
harms/illnesses most times only appearing many years after exposure. The same holds true for
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This is a personal email address.
Mark Safe Report Powered by Mimecast
those of us who end up being exposed to the toxins and microplastics that are a result of wear on
the artificial surfaces. Why should I suffer because of some perceived benefits to the small
percentage of community members who claim they cannot live without soccer fields or playgrounds
made from artificial materials? I know that most in the soccer world actually do prefer natural grass
– especially if its maintained properly.
Its time to do the right thing and think about how change is possible and how we can all benefit by a
healthier, more sustainable future. We should not burden future generations with possible health
issues, cleaning up toxic messes, nor overflowing landfills.
Medical and environmental research is still ongoing and continually finding more and more reasons
why we need less UNESSENTIAL plastics – including artificial ground covering.
Please do not approve the Lloyd study. Please strongly look into how you can provide the best
organically managed, natural grass playing fields for all. A pilot program as recommended by both
Lloyd’s and your own Parks and Rec commission is a step in the right direction. And why not make it
El Camino park – rather than cover it with more toxic, plastic grass?
I appreciate your considering all the ramifications of the decisions you make on Monday night and if
at all not 100% sure you are doing the right thing, please delve a bit deeper into how to do what's
best for your community as a whole and future generations and not just a smaller subset of sports
teams.
Thank you.
Andrea Wald
From:Manny Diaz
To:Council, City
Subject:Turf Study
Date:Thursday, November 13, 2025 10:35:51 AM
Attachments:11.13.25 - TenCate Letter to Palo Alto City Council.pdf
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Dear Mayor and Council Members,
Attached is a letter from CEO Joe Fields of TenCate Grass regarding the turf study issue that
you will discuss at your November 17, 2025 Palo Alto City Council meeting.
Thank you for your consideration.
Manny Diaz
Consultant for TenCate Grass
Manny Diaz & Associates inc.
This message needs your attention
This is a personal email address.
This is their first email to your company.
Mark Safe Report
November 13, 2025
Palo Alto City Council
City of Palo Alto City Hall
250 Hamilton Avenue
Palo Alto, California 94301
RE: Draft Study on Synthetic and Natural Turf Athletic Fields
Honorable Mayor Ed Lauing, Councilmembers Patrick Burt,
George Lu, Julie Lythcott-Haims, Keith Reckdahl, Greer Stone,
Vicki Veenker
Thank you for your consideration and the thoughtful approach you’re taking in evaluating the
best surfaces for Palo Alto's municipal park system. We appreciated the opportunity to speak
with Lloyd Sports + Engineering as they prepare their study on synthetic and natural turf
athletic fields.
In response to the publication of the draft report, we wanted to follow up and reiterate the
immense value of artificial turf and the recent technological advances that ensure the health
and safety of the athletes and communities that use synthetic turf, which the study included.
These are important factors that we hope the Commission will consider as the turf study
process continues.
TenCate’s Leadership and Commitment to Safety and Sustainability
1. Established Track Record
TenCate Grass is the largest manufacturer, distributor, installer, and recycler of artificial turf in
the United States—and a global industry leader. We recognize and respect the concerns
surrounding artificial turf, and in response, we have devoted significant resources to developing
more sustainable turf systems. Numerous independent studies and comprehensive research
reviews have repeatedly demonstrated the safety of artificial turf. Our continued work reinforces
these findings and ensures that our products meet or exceed health, safety, and environmental
standards.
2. Advanced Turf Solutions & Research
Our latest innovations exemplify our dedication to safer and more environmentally friendly
turf systems. Below are some key updates:
• PFAS-Free Since October 2023: We proactively eliminated the use of PFAS in our turf
manufacturing processes to address public health concerns.
• No Performance Infill Required: Our newest turf, Pivot®, requires no sand or black crumb
rubber. By removing traditional infill, primary microplastics pollution is eliminated and the
surface can be 30–50 degrees cooler than turf systems using rubber and/or conventional
abrasive materials.
• Equivalent Injury Rates: Independent studies by the NFL and NCAA demonstrate no
difference in injury rates when comparing artificial turf to premier-quality natural grass
stadium fields. Indeed, research shows that turf can be significantly safer than regularly
used grass fields, such as those used by high schools and community parks.
• Recyclability: Turf systems can be recycled. TenCate has a turf recycling center in
Louisiana where we have processed a number of fields from California—including a field
recently removed from Stanford University. In 2019, TenCate also led the way by
establishing recycling capabilities in the Netherlands where now over 95 % of turf fields are
recycled.
• Water Conservation: Artificial turf uses significantly less water than natural grass fields—
an important factor in water-sensitive regions.
• Chemicals: Unlike natural grass fields, artificial turf fields do not require the use of any
pesticides, fertilizers or herbicides (many of which contain PFAS or are classified as PFAS)
– all of which contaminate the soil in and around natural grass fields and can find their way
into our water.
• Increased Playability & Equity: Artificial turf dramatically increases playing availability
compared to natural grass fields, enhancing community access.
Conclusion
We value the feedback from environmental and community groups and acknowledge the
importance of ongoing engagement with all stakeholders. Thank you for the opportunity to
share the facts about artificial turf and for the thoughtful approach the City of Palo Alto has
taken thus far. TenCate remains committed to working with you, your staff, and all stakeholders
to ensure that residents benefit from the proven advantages of artificial turf while safeguarding
public health and the environment.
Should you have any questions or wish to discuss these topics further, please feel free to
contact us. We look forward to the opportunity for continued collaboration.
Thank you for your consideration.
Very sincerely,
Joe Fields
CEO Americas,
TenCate Grass
From:Magdalena Cabrera
To:Council, City; Lauing, Ed
Subject:Fwd: Nov 17 decision on Lloyd consulting findings
Date:Thursday, November 13, 2025 7:04:30 AM
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Esteemed council members and Mayor,
I write to you once again to urge you to consider very carefully the vote to accept or reject the findings of the Lloyd
study on artificial turf. As the saying goes, buyer beware!
There is Too much hard science out in the world that tells us that the toxic chemicals in artificial turf are abundant
and dangerous to all living things. Nano and micro plastics abound in the environment, in your bodies and in mine.
There is NO place on earth without nano plastics in evidence. Think of that! NO place on earth.
In my humble opinion, there is no good reason to keep using artificial turf or PIP rubber. If we do a serious
cost/benefit analysis, one that is deep and looks long term, I believe with all my heart that we will understand that
the cost far exceeds the benefit.
Let us be the city of LIght and Good Sense. Let us lead the way and be the shining example of doing the right thing
, inspiring other cities to follow our stellar example in protecting our citizens and the environment.
Vote no on the less than objective Lloyd study. Think about the warning In Dr Suess' The Lorax or in the Joni
MItchell song "Big Yellow Taxi" we listened to when we were young: " Don't it always seem to go that you don't
know what you've got till it's gone. Paved paradise, put up a parking lot."
Respectfully,
Magdalena Cabrera
long time resident of the Ventura Neighborhood
PS: Thank you for the grass field at Boulware Park. The first effort at "meadow" was , as you know, not at all
appealing or usable. This is a huge win for everyone.
PSS: Open the attachment if you are unfamiliar with the prescient lyric by Joni Mitchell.
https://jonimitchell.com/music/song.cfm?id=13
More on nano plastics:
https://www.sciencedirect.com/science/article/pii/S2772416622000146
From:Sue
To:Council, City
Subject:Organically-Managed Natural Grass Field Pilot Project
Date:Wednesday, November 12, 2025 10:03:57 PM
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!
Dear Mayor Lauing and Palo Alto City Council Members:I am writing to urge you to support a pilot program to design, build, and maintain a high-quality organically managed grass field in Palo Alto. A most useful recommendation fromthe Lloyd study is to implement such a pilot project to demonstrate best practices andcollect reliable data on performance, cost, and usability.
A well-designed pilot would allow Palo Alto to directly compare the costs and carryingcapacity of a high-quality organic field, using drought-tolerant grasses and good surfacedrainage. In other regions, well-maintained organic fields have provided up to 2,000 hoursof play per year—meeting community needs while eliminating pesticide use and syntheticturf waste.
El Camino Park would be an ideal location for this pilot. Planning could begin this year,with sod installation to shorten the timeline for completion. Its lighting would also allowextended play hours that most local grass fields do not currently offer. Choosing to moveforward with a natural grass pilot—rather than installing more plastic turf—would reinforcePalo Alto’s reputation as an environmental leader and help avoid the documented harmfulenvironmental and human health impacts of synthetic turf before, during, and after its lifecycle.
The Lloyd study provides limited detail on pilot design. Based on successful exampleselsewhere, the following elements are recommended:
Partner with the county, nearby cities, and the school district to share costs and dataregionally.Develop the plan with guidance from agronomists who have experience designing andmaintaining successful organic grass fields. Beyond Pesticides and similarorganizations will offer expert assistance at very low cost.Avoid a sand-capped field. Instead, amend native soils with organic material and aerateregularly to provide internal drainage; ensure smooth surface grading and a slight crownfor surface runoff.Install high-efficiency irrigation, such as MP rotators, to mimic rainfall and reduce water
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This is a personal email address.
Mark Safe Report
use, drift, and puddling.Select grass species known for durability and year-round usability, including warm-season grasses suited to California’s climate.Use soil-building organic management practices that add carbon and nutrients whilereducing runoff to storm drains.Increase the maintenance budget and ensure strong accountability through detailedcontracts. Require maintenance logs, photo documentation, and performance-basedpayments.Include consistent gopher control and prompt repair of holes, ruts, and uneven areascaused by wear or animals.Implement a simple online community reporting tool for issues such as gopher holes,irrigation malfunctions, or field condition concerns.Use adaptive management to refine practices as field monitoring data are collected.This pilot would provide valuable insights into long-term cost-efficiency, resilience, andcommunity satisfaction while modeling environmentally responsible land management. Ihope the Council will seize this opportunity to lead regionally in sustainable, safe, andhigh-quality athletic fields.
Thank you for considering this important initiative. I would be happy to share moreexamples or connect staff with experts in organic turf management.
Sincerely,
Sue Chow, City Resident
From:Leanne McAuliffe
To:Council, City
Subject:Action Item 9: Approval of the Study and Assessment of Turf Systems -
Date:Wednesday, November 12, 2025 7:42:33 PM
Attachments:TTT pg1.png
TTT pg 2.png
TTT pg 3.png
TTT pg 4.png
TTT pg 5.png
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
i
Dear Palo Alto City Council Members,
Please take a few minutes to read the information in the link below regarding Industry Tactics
(Test the Turf Collaborative, 2025). This should help you understand the sheer frustration of
community members trying to educate and advocate for natural grass fields.
Community members are desperate to get good sports fields for our kids and many have
shared a plethora of information as to why natural turf is a holistically safer option than plastic
turf. (Safer for the health of kids, the environment and public funds.)
Since El Camino is already plastic, is the horse already out of the barn? Yes. But that doesn't
mean the decision can't be made to revert fields back to natural turf (which can take
substantially less than 18 months!) and stop any further damage.
Over the past 5 years of following and researching the topic of artificial turf I have seen
industry narrative morph from 1st Dog Defense (no harm) to 2nd Dog Defense (no risk) to
3rd Dog Defense (low risk) within our county, state and nationally. I then came to the
unfortunate realization that grass advocates and independent experts have in fact done the
plastic turf industry a huge favour because we have shared so much well researched,
documented and referenced information with decision makers (like you) that if industry has to
play the 4th Dog Defense (you knew) card then no one supporting or approving the installation
of plastic turf will be able to say they didn't know the risks. So can we please just stop the
madness now BEFORE industry needs to play the 4th Dog Defense card.
This message needs your attention
This is a personal email address.
This is their first email to you.
Mark Safe Report
Don't approve the report in its current form.
Take the time to understand and acknowledge the risks of plastic fields as documented
by independent experts and have these incorporated into the report.
Consult independent Certified Sports Field Managers experienced in well designed,
installed and organically managed natural turf sports fields and have this information
incorporated into the report.
Approve conversion from plastic sports fields back to natural turf.
Take the multiple millions that would have gone into plastic fields and instead invest it
in properly maintaining natural turf fields. (Invest in our kids health, local jobs, and the
environment and not the profit driven multibillion dollar plastic industry.)
We can't change the beginning, but we can stop where we are and change the ending.
Kind regards,
Leanne McAuliffe
Santa Clara County resident
https://www.testtheturf.org/industry-tactics.html
NB: In the event that the link doesn't work for public comments I've attached screen shots of
this web page. (TTT pages 1-5)
From:Claire E
To:Council, City
Subject:November 17, 2025 Agenda Item #9, Approval of the Study and Assessment of Turf Systems
Date:Wednesday, November 12, 2025 7:15:17 PM
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i
November 12, 2025
Dear Council Members,
Thank you for the opportunity to comment on Agenda Item #9, Approval of
the Study and Assessment of Turf Systems. Unfortunately, the turf study by
Lloyd Sports and Engineering, is not an unbiased assessment of the
options and vital information is misleading or missing that is needed to
select an appropriate turf system for any of Palo Alto’s parks.
I have detailed a number of concerns with the study. I believe that the right
solution is to move quickly to instead and adopt the Lloyd study and staff
recommendation to implement a natural grass pilot project, not at some
point at some undisclosed location but as soon as possible, and at El
Camino Park. Natural grass is healthier, provides more aesthetic appeal
and ecological value, has a lower carbon footprint and can (if well designed
and maintained) provide many more hours of use than the Lloyd study
concludes.
Please consider my points listed below when reviewing the staff report and
Lloyd study in preparation for the November 17th meeting.
Thank you!
Claire Elliott, Palo Alto resident
Points to consider for November 17th:
1. The Lloyd study should not be approved in its current biased and
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incomplete form: A large concern is the poor attention paid to the health
impacts of synthetic turf.
b) The “Heath Hazards” section lists one chemical health hazard for
synthetic grass (PFAS) and several for natural grass, even though the
chemicals listed for natural grass are all pesticides that Lloyd must know
Palo Alto does not use.
c) The report downplays the PFAS concern by saying the city can
procure PFAS free turf.
d) This is a serious problem because it is not yet possible to confirm
any product is PFAS free
e) A large number of PFAS compounds that could be incorporated into
feed stocks used by the turf manufacturer and many of these compounds
have no approved analytical method to identify their concentration in a
material.
f) In addition, synthetic turf often contains a large number of
compounds besides PFAS that are known to be toxins, carcinogens
and endocrine disruptors.
g) Also, during its use, plastic grass blades often break off and then
turn into microplastics which are known to have many negative health
impacts and are being found in many parts of our bodies.
2. A second concern is uneven focus of environmental concerns for all
three turf types evaluated by the study.
a) No mention of PFAS as an environmental contaminant is made,
the only environmental concern listed for synthetic turf is the release
of microplastics.
b) For hybrid and natural grass, carbon footprint and water use were
described, but not for synthetic turf even though its carbon footprint is
high and water is used in washing and cooling the turf. Sometimes
antibacterial solutions are also used which can be released into the
environment.
c) No other chemical releases from synthetic grass is mentioned
(like health impacts they should have include the thousands of
chemicals that may be included and leached out of synthetic turf,
including many that are toxins, carcinogens and endocrine disruptors.
3. The cost figures are misleading in the final report.
a) The cost per hour calculated for natural grass fields assumes
these fields are only used for an average of 500 hours per year when
used over 1,000 hours per year.
b) The cost per hour for synthetic turf assumes El Camino was used
for 2,700 hours per year. This calculation included some “double-
dipping” because when the two halves of the field were used at the
same time, two instead of one hour was used. The consultant
admitted if this method is changed, the usage would be 1,900 instead
of 2700 hours per year. It should be changed because the cost for
installing and maintaining the fields is based on the full-sized field, not
half of a field!
c) When you redo the cost estimate per hour of usage, these
corrected numbers result in the cost per hour for grass changing from
$179 to $89 and synthetic turf changing from $79 to $92. Showing
natural grass can cost less per hour of play.
d) The cost for synthetic turf would go up further from $92/hour
of play if you include the cost for recycling the turf which was
left out of the study.
e) The cost for synthetic turf would go up even farther if the study
included an estimated cost for the environmental and health impacts
of synthetic turf during manufacture, use and disposal.
f) In the October 28th Parks and Recreation meeting, the Lloyd
consultant stated that recycling turf is expensive so the turf might be
repurposed for batting cages, as substrate for horse arena soils or
shipped south of the border. What is the eventual fate of these
“repurposed” turf fields?
g) What is the economic impact of synthetic turf chemicals and
microplastics in our soil and waterways, the cost to clean up
contamination caused by reuse and disposal, or the price of medical
bills and shortened life spans for those in plastics manufacturing
industries who are known to have significantly higher cases of many
diseases?
4. One recommendation of the Lloyd study that makes a lot of sense is
to design and implement a pilot project of a well-designed and
maintained grass field.
a) This would allow Palo Alto to gather data to compare costs and
carrying capacity of a high-quality organic grass field with drought
resistant grasses and good surface drainage. These types of fields
have been shown in other parts of the country and world have
provided up to 2,000 hours of use per year.
b) This pilot project would be ideally implemented now at El Camino
Park. The design could start this year and by installing sod instead of
seeding you could shorten the project timeline.
c) The lighted field at El Camino would also allow extended play
many grass fields in Palo Alto do not offer.
d) Saying no to plastic grass and implementing a natural grass pilot
project would help Palo Alto maintain a reputation as an
environmental leader and avoid the well-known environmental and
human health impacts of a synthetic field before, during, and after its
useful life.
The Lloyd study gives little detail about what a pilot project design
should include. Consider these details:
a) Partner where possible with the county, other cities in the region,
school district, etc, so the costs and results can be shared regionally
b) Develop the plan with expert help of agronomists who have
already had success designing and maintaining organic grass fields.
Beyond pesticides may be able to provide some of this expert help at
no or low cost to the city.
c) Save money and water and make organic management more
successful by NOT using a sand capped field. Provide internal
drainage by amending the native soils with organics, and aerating
often. Provide surface drainage with careful grading that provides a
smooth surface with a slight crown in the middle.
d) Include high efficiency irrigation (e.g. MP rotators) to mimic rainfall
and reduce drift and puddling of water.
e) Selects a grass species that has been shown to allow additional
play time (possibly a warm season grass that has been shown to work
in California.)
f) Use organic management that adds carbon and nutrients that are
less likely to runoff into stormdrains.
g) Grass field monitoring and maintenance is critical. Increase the
budget for these necessities. Ensure contracts for maintenance are
detailed, hold back funding to ensure the contractor performs well.
h) Control gophers and fill holes and ruts caused by animals, people,
vehicles, etc.
i) Ensure maintenance protocols are detailed in contracts and
funding held aside until contractors prove they are following the
documentation of improvements made.
j) Develop an easy to access and use crowd sourcing method of
evaluating field conditions (online tool for reporting gopher holes,
irrigation problems leading to dry or soggy conditions, etc.
k) Use adaptive management to alter practices as results from
monitoring show improvements are needed.