synturf letter


To: The Honorable Edwin M. Lee

Mayor of the City and County of San Francisco.


Dear Mayor Lee,

At the personal request of former Mayor Gavin Newsom,

we are sending your office an abbreviated report regarding

questions of public health and the environmental impact in respect to the continued introduction of synthetic turf

into San Francisco open public spaces and San Francisco sports play-fields.


The following people and groups are responsible for, or been an inspiration for, this report;

-  Paul Pelosi Jr. (past president of the SF Commission on the Environment),

-  the San Francisco Recreation and Parks Department & management (Phil Ginsburg - general manager, Yomi Agunbiade - past-gm),

-  the San Francisco Recreation and Parks Commission, (Mark Buell - president, Jim Lazarus past-president),

        - (Tom Harrison, Gloria Bonilla, David E. Lee, Meagan Levitan, Larry Martin, Paige Arata, Michael J. Sullivan)

-  Bob, Bill, & John Fisher and Susan Hirsch (Pisces Incorporated / City Fields Foundation),

-  the SF Department of the Environment and the SF Department of Public Health

-  a coalition of philanthropic groups and public health specialists.



a) cancers

b) thyroid effects

c) neurological effects

d) developmental effects

e) allergens and their impact on asthma sufferers

f) skin, eye, and respiratory irritation,

g) bacterial infections, including MRSA (methicillin-resistant Staphylococcus aureus) "superbug"

 (Tire crumb contains 15 metals which are currently listed as oral carcinogens including mercury, arsenic, lead, cadmium, benzene trichloroethylene, aniline, naphthalene.)




1) epoxies and adhesives,

2) polypropylene plastic with plastic “blades”,

3) tire waste crumb infill, (used throughout San Francisco by City Fields Foundation c/o Pisces Inc.)




The plastic parts of synthetic turfs contain;

a) phthalates / Di(2-ethylhexyl) phthalate (DEHP)

b) lead (lead paint has been banned from synthetic fields in CA since Jerry Brown’s 2009 “AstroTurf” law suit)

c) volatile nitrosamines.



The Styrene-Butadiene-Rubber-SBR tire waste used in San Francisco synthetic fields contains;

a) chemicals (including benzothiazole, butylated hydroxyanisole, n-hexacane, 4-(t-octyl) phenol, etc.),

b) heavy metals (including lead, mercury, arsenic, selenium, cadmium, zinc [up to 14 times the national standard].

c) carbon black (an elemental carbon at the nanoparticle level, responsible for carcinogenic and inflammatory effects).

 d) polycyclic aromatic hydrocarbons (PAHs) and volatile organic chemicals.


        As was the case for years in regards to asbestos, lead paint, and cigarette smoking; the epidemiology of the environmental and human health risks associated with exposing large quantities of ground tire waste in public spaces have yet to be credibly studied. The health risks to humans, pets, and wildlife of inhaling, ingesting, or coming in contact with the deteriorating tire crumb and its nano-particulates to date are not definitely known. This is partly because the faddishness of the new technology as well as a current shortage of funding. The manufacture of tires is not regulated by any public health government agency.


Why is synthetic turf becoming an issue of increasing concern in San Francisco?

Tires are not intended to have an "end use" involving pulverization. Never has so much carbon black been concentrated to such a degree and volume in a commercial product designed to come in intimate contact with humans, especially children, over long periods of time.

        Tire crumb, (and plastic blades), enter the body through skin, ingestion, inhalation, or any orifice such as the eyes or ears. Its sharp edges have been found to act as an irritant to tissue that it contacts or organs it becomes lodged in, including the folds of the alimentary tract and lungs. Tire crumb can become trapped in the body for extended lengths of time causing inflammation and bringing infection compromising the body’s immune system.

The loose tire crumb and dust particulates migrate off of San Francisco installations by;

a) wind, (strong coastal),

b) host; (clothing, hair, shoes, etc.),

c) drainage; (storm and sewer drains),

d) leachate / seepage,

e) ingestion and inhalation (by pets and humans as well as by various forms of wildlife throughout the food chain ).


The ground up tire waste used in San Francisco fields comes from various parts of the tire (sidewall, inner lining, tread, etc.), and the tires used are manufactured in various factories throughout the world, (over 60% of tires in U.S. landfills are manufactured outside of the United States.). Therefore; since the tire waste is not a homogenized blend, no sampling of the tire crumb can or will be truly indicative of any other sampling or of the total. The tire dust and crumb breaks down into nanoparticulates.


“The Truth About Synthetic Turf”                

or the CBS-5 report KPIX-TV, San Francisco






The synthetic turf industry and their San Francisco lobbyists claim benefits of removing grass fields and substituting them with artificial materials. As with asbestos, lead paint, and cigarette smoking; the epidemiology of the environmental and human health risks associated with dispersing large quantities of ground tire waste in public spaces is of growing concern. Moratoriums have been proposed and enacted around the world, including by the San Francisco Board of Supervisors in 2009, (resolution 091045).


How much plastic is used in the City of San Franciscos’ synthetic sports playfields (to date)?

Based on Jared Blumenfelds’ computations, the city of San Francisco’s current investment in synthetic turf plastic

is more than the equivalent of 184,470 gallons of oil or 4392 barrels of oil.

This plastic will need to be discarded and replaced approximately every 8 years as per manufacturers.


How much tire crumb is currently dispersed in the City of San Francisco synthetic sports playfields?

To date, the City of San Francisco has introduced over 16 billion pounds of pulverized tire crumb into its public spaces. The tire crumb used on synthetic fields passes through a fine screen mesh which allows through all material smaller than 100mm, including nano-particulates.


Where does the tire waste used on San Francisco playfields originate?

The tire waste originates from all over the world. “The different brands of tires used almost certainly contributed to the variable levels of chemicals released”.

- Evaluation of Health Effects of Recycled Waste Tires in Playground and Track Products” Jan. 2007,

State of California, Integrated Waste Management Board


For decades, the tire industry has had the technology and capability to manufacture a tire whose life span exceeds the life of multiple car applications.

In 2002 the international tire consortium Aliapur, (Goodyear, Bridgestone, Continental, Dunlop, Kleber, Michilin, Pirelli) was founded to address their growing public relations headache of accumulating tire waste. Instead of promoting an environmentally responsible approach the tire consortium, like the auto industry, chose to continue their more profitable business model of creating a product of rapid obsolescence. This has resulted in an enormous amount of tire waste. (1 billion tires are discarded annually world-wide. Current figures published by the US Environmental Protection Agency (EPA) state that approximately 290 million used tires are discarded just by Americans every year.

To address public pressure, the consortium engaged in a campaign of creating a public perception of the safe recyclability of pulverized tires.

Out of this campaign arose FieldTurf Tarkett, (and other companies like it), to manufacture synthetic turf with tire crumb infill. Using their considerable resources, they have effectively exploited weak economic conditions and panicky, cash strapped cities, parks departments, and schools. FieldTurf alone produces over 219 million square feet of polypropylene surface a year.



The San Francisco Recreation and Parks Department will soon release an Environmental Impact Report, (EIR), for their proposed grass to synthetic turf conversion of the Golden Gate Park - Beach Chalet fields. This EIR will also pertain to the green-lit conversions in San Francisco's District 11, (Ocean View Playground), and District 8, (Mission Playground).

We have included submitted scoping guidelines for this EIR below.







    This Environmental Impact Report, (EIR), will have an impact far beyond the borders of the City and County of San Francisco.

There is a popular TV show today called “Mad Men” based in the 1960’s. Part of the humor in the show comes from recognizing societies past follies. It’s amusing to us today to see images of children being allowed to run around with plastic dry cleaning bags on their heads, or pregnant mothers-to-be binge drinking cocktails, exhaling second hand smoke in their children’s faces, as they watch them chew on lead painted toys. The reason we can find this amusing is because our culture has evolved to where we now consider such behavior ludicrous.

So how is it that an enlightened society like San Francisco has come to believe that it’s a good idea to introduce 100s of tons of loose pulverized tire waste into public spaces which even the manufacturers freely acknowledge contains unregulated chemicals and heavy metals? Specifically for a sport like soccer that all but necessitates that children athletes kick up its toxic dust into each others faces as they hyperventilate it deep into their lungs.

This issue isn’t unique to San Francisco, and history shows us that just like lead paint, and asbestos before that, it will take time before we as a culture will catch on to its long term risks.

Synthetic field lobbyists for just over 10 years now have been aggressively pushing synthetic fields onto well intentioned but poorly informed municipalities, much like in the “Mad Men” days when the tobacco industry had Ronald Reagan and medical doctors smilingly proclaiming the health benefits of cigarettes and other such self-serving propaganda.

The intention of these scoping guidlines is to address such misinformation.


    Today we hear from sources in cities throughout the world that are reporting that synthetic turf salesmen

have been effectively promoting their products by declaring that,

“they don’t have any problem with synthetic turf in San Francisco”.


    The goal of the following guidelines is to participate in creating

an Impact Report worthy of the reputation and standards befitting the citizens of San Francisco, both today and in the future.






    It should be noted in the report that;

a) converting the pre-existing natural grass of the Golden Gate Park Soccer Fields to plastic and tire waste does not create more playfields. It will in fact decrease the existing playfields potential use for most recreational activities other than soccer.

b) currently The City of San Francisco has well over 30 acres of synthetic soccer fields.

  (It may be worth noting in the report that, since its inception, the City Fields Foundation has yet to create a single square inch of new playfield, and has instead only eliminated over 20 acres of multi-use grass neighborhood playfields.)

    Any and all calculations should be accounted for and rationally explained, and should include;

a) comparative calculations with grass fields with similarly installed drainage,

b) the exclusion and loss of any activities prohibited by synthetic surfaces; including picnics, festivals, or fairs that involve structures, stakes, food, sports drinks, or any drinks other than water,

c) the loss of available play time use for other sports, including the exclusion of current and future sports that require a stake or spike, (i.e. volleyball, croquet, footbag/hackeysack, or any sports that require a metal cleat, etc.),

d) all calculations used should be clearly laid out and explained. (i.e. Do the re-calculations involve relining the fields to squeeze in smaller fields and or the overlapping of fields like soccer and baseball?)

(It is worth noting that the Garfield Synthetic Playfield is locked during the day except for league play.)


    It should be noted in the report that the conversion of a natural grass playing surface to a gravel/plastic tarp/ground tire based surface will effectively eliminate their use for the majority of sports and recreational activities.

Any “efficient” benefits should be defined and a proper survey should be made of citizens of San Francisco that is not limited to simply commercial soccer league operators and their participants, or groups receiving funding from City Fields Foundation members, or other groups and individuals with a vested interest.


         It should be noted in the report that San Francisco’s current maintenance program does not adequately, if at all, address the bacteria buildup that is associated with organic material, (food, gum, blood, sweat, saliva, fecal material, and other general organic decay, etc.), that is regularly collected in a synthetic turf’s inorganic medium.

If any claim is made to the contrary, then past maintenance schedules and work-logs should be provided for existing San Francisco artificial fields as well as purchase orders and receipts for the required disinfectants.

The manufacturers maintenance requirements should be included for existing San Francisco synthetic playfields, which include but are not limited to caustic solvents which are required to remove old bubblegum from the mesh. (specific manufacturers to include  FieldTurf, Sportexe, etc.),

 Other required regular treatments include algaecides, products to mask the odor, and various specialized cleansers.



       It should be noted in the report that currently the Golden Gate Park Soccer Fields do not use fertilizers or pesticides.

(It should be noted - Board of Supervisors INTEGRATED PEST MANAGEMENT PROGRAM Ordinance amending the San Francisco Environment Code by amending Sections 300, 301, 302, 303, 304, 305, 306, and 308, adding Section 310, and repealing Section 307.)


        It should be noted in the report that the Golden Gate Park Soccer Fields will have access to the forth coming PUC recycled water project.

       The report should also include any warranty-required water cleaning schedules as outlined by the synthetic turf manufacturers. New state of the art drought resistant and durable grass hybrids should be listed.


        Studied injuries should include but not be limited to;

a)      ACL (Anterior Cruciate Ligament injuries)

b)      muscle strains and spasms,

c)      turf  “burn”,

d)     turf toe,

e)      footlock

f)       infections including MRSA (methicillin-resistant Staphylococcus aureus) "superbug" outbreaks,

g)      cancer clusters associated with athletes playing on synthetic fields.

        It should be noted in the report that the synthetic turf’s plastic tarp and loose tire crumb sit upon a bed of gravel.

As the tire crumb migrates and puddles, “shallow” areas develop that create injury vectors with the gravel base.

Multiple studies and surveys should be provided including the bi-annual NFL Players Association survey.

(San Francisco Examiner - )    



        It should be noted in the report that cryogenic cleaning does not involve the removing of heavy metals, chemicals, or elements, it simply refers to a process for physically breaking down tire material into smaller particles.



       The impacts of the “improvement” must be listed and studied and should include but not limited to;

a) the long term ongoing replacement fiscal responsibility placed upon future San Francisco taxpayers

b) the impacts of introducing pulverized and degrading industrial chemicals and heavy metals into public spaces,

c) the restriction of allowed activities by users of the public spaces,

d) the environmental impacts of converting a natural grass field to a synthetic.



        A thorough and detailed comparison of the long as well as short-term impacts of replacing a living environment, (soil, plants, and wildlife) with tires/plastic should be conducted,

including but not limited to:

a) heat island effects,

b) loss of CO2 sequestration,

c) loss of O2 production.


       If a rise in childhood obesity can be found that correlates with the increased loss of grass playfields and the increase of synthetic turf playfields, then that should be clearly noted in the report. 


There should be included;

a) a survey of existing and upcoming mower technology, (including but not limited to battery and electric).

b) a survey of existing and upcoming athletic field grass hybrids,



        ADA disability restrictions in regards to the various manufacturers warranty and recommendations regarding synthetic fields access to wheeled conveyances as well as crutches.


        An environmental impact study should be made comparing a simple gopher barrier installed on a grass playfield compared to the 5 foot concrete sunken retaining walls that are required to control the chemical leachate of artificial fields.



        The fragile nature of the materials used are vulnerable to accidental and purposeful damage.

Warranties may be void if the fields are not protected during non-athletic events.

The cost of acts of vandalism to both synthetic fields and grass fields should include but not limited to;

1) graffiti, (tagging or other painted messages),

2) arson, (synthetic turf, even that which is treated with fire-retardant, will melt if set on fire with an accelerant like gasoline).

3) purposeful biological vandalism.








City Fields Foundation C/O Pisces Inc. is a 501(c)(3).

The foundation managers are

a) John J. Fisher

      1) president of Pisces, Inc. an investment management company for the Fisher family.

      2) a partner of the private investment partnership of the Fisher family.

b) Robert J. Fisher (founder and chairman of a general contractor and construction management company, Fisher Development, Inc.)

c) William S. Fisher (founder and CEO of a private equity fund)


        It should be noted in the report that the leadership of City Fields Foundation C/O Pisces Inc. is comprised of;

a) management of the San Francisco Recreation and Parks Department,

b) paid lobbyists including Susan Hirsch of Hirsch & Associates whose listed clients include "The Fisher family" and City Fields Foundation,

c) owners of construction firms that have profited, and/or whose associates stand to profit, from the construction of synthetic fields in San Francisco, (including but not limited to Fisher Development, Inc. and Baycor Builders, Inc.). (Matt Lockary, City Fields “Team member” and president of  Baycor Builders, at one time listed on his Baycor web site that they had a business arrangement with City Fields / City of San Francisco for over $50 million dollars).

d) other groups, individuals, and non-profits with vested and dependent financial interests.


        It should be noted in the report that City Fields Foundation C/O Pisces Inc. introduced hundreds of tons of pulverized tire waste into the congested Fillmore neighborhood, (the Kimball Synthetic Playfield which is directly adjacent to KIPPS Bay Academy, [an investment project for many of the City Fields Foundation management team members]),

during a period of time in which;

a) the San Francisco Board of Supervisors had called for a moratorium on the installation of new synthetic fields,

b) multiple state reports investigating the health and environmental issues regarding synthetic fields in California was, and are still, outstanding, (as mandated by California State Senate bill SB 1277),

c) for years, both City Fields Foundation C/O Pisces Inc. and San Francisco Recreation and Parks repeatedly fought the EIR process by campaigning and invoking special exemptions.


        it should be noted in the report;

a) that strict instructions were given to its participants to specifically not consider the option of natural grass,

b) that the formation of the task force was never widely or formally publicly announced or agendized by the

Recreation and Parks Commissioners or the SF-RPD General Manager,

c) that many members chosen were found listed with the City Fields Foundation as “supporters”.

(An undeclared second PROSAC member and City Fields Foundation supporter was improperly picked to fill a citizen spot.)

        The 5 San Francisco citizens who were kept off of the task force included;

            1) a neighbor who lives down-wind from San Francisco’s Silver Terrace synthetic soccer complex,

            2) an informed medical doctor, on the topic of synthetic turf issues,

            3) a long time San Francisco soccer league representative who advocated “The Precautionary Principle”,

            4) Two San Francisco neighborhood association officers who had initiated scrutiny and had been asked by 5 other neighborhood associations to represent them on the task force.),

d) that none of the “11 environmental and health issues of public concern” listed by the report were, or could be, resolved by the limited internet web searches that were employed,

e) the poor attendance record of many of the participants.

(The lone medical doctor on the task force only showed up for the opening statements and the final recap day. He wasn’t available to give or discuss any assigned reports, including his own.)


        It should be clearly noted in the report that previous required Environmental Impact Reports,

(pursuant to the California Environmental Quality Act (CEQA) Guidelines section 15166),

have been successfully and actively fought for years by both the management of the SF-RPD and the management of City Fields Foundation C/O Pisces Inc.

        It should be clearly and prominently noted in the report that the San Francisco Recreation and Parks Department, (SF-RPD), oversaw the selection of the chosen consulting firms to assist on what the SF-RPD characterized as a “controversial project” (page 5 “Request for Proposals…”),

It should be clearly noted in the report that the authorship of this report is being overseen, managed, and vetted by San Francisco Recreation and Parks Department, (SF-RPD) and members of City Fields Foundation C/O Pisces Inc.




It should be clearly noted in the EIR,

the age of the particular infill that any and all studies, or tests, were performed upon.

Studies that do not specify are misleading.

Tires, and the resiliency of the carbon black, ossify over time and become hard and brittle.

Additionally, the infill becomes compacted.

To quote a representative of the FieldTurf corporation in regards to the infill at Silver Terrace (San Francisco),

“it (the infill) will become hard as rock in a few years”.




The San Francisco Recreation and Parks Department claims that no cleaning maintenance is necessary

other than periodic sweeping of debris and applications of soap and water.

This is contrary to virtually all credible synthetic turf recommended guidelines and warranties.


MRSA (methicillin-resistant Staphylococcus aureus), "superbug", is a difficult to treat bacterium associated with athletic equipment and artificial fields and is especially troublesome around open wounds.

A study published in the New England Journal of Medicine linked MRSA to the abrasions caused by artificial turf. Three studies by the Texas State Department of Health found that the infection rate among football players was 16 times the national average. In October 2006, a high school football player was temporarily paralyzed from MRSA-infected turf burns. His infection returned in January 2007 and required three surgeries to remove infected tissue, as well as three weeks of hospital stay.


The members of SFPARKS have posted short videos pertinent to your deliberations that can be found on YouTube.

at YouTube type in “sfparks turf”


 This Environmental Impact Report will be referenced

regarding the replacement of acres of neighborhood grass parks with synthetic surfaces

for years to come.

         It will have both a long and short term impact on;

a) the public health of San Francisco neighborhoods,

b) San Francisco neighbors, pets, and wildlife

c) San Francisco's surrounding environment, ( including the Pacific Ocean and the San Francisco Bay)

d) financial liability to future San Francisco tax payers.