HomeMy WebLinkAboutZoning Board Public Comment, Yayoi, April 22 2025, Game Farm Road Synturf ProjectEarth Day, April 22, 2025
Re: Cornell’s Synthetic Turf Project – Testing Concerns and Minimum Requirements
Dear Town of Ithaca Zoning Board of Appeals Members,
Cornell has repeatedly stated that PFAS testing for the proposed synthetic turf field will be
conducted by the manufacturer, and that “independent third-party testing” will occur “prior to the
turf leaving the manufacturer.” This language has not changed, despite public objections, and
continues to raise serious concerns.
➤ Manufacturer-conducted testing is not independent
➤ Testing coordinated and paid for by Cornell—conducted before the turf even leaves the
factory—is not independent
Independent testing matters because numerous studies have confirmed the presence of PFAS in
synthetic turf materials. In fact, TenCate/GreenFields’ own technical manual for one of its
widely sold turf products—Pivot—explicitly states that it contains PFAS. We have submitted the
manual to the planning board.
If Cornell is using or considering that product, the public has a right to know. The Zoning Board
should recommend that the Planning Board require Cornell to disclose the full technical manual
of the specific turf products under consideration.
Further, a Freedom of Information Law (FOIL) request revealed that both the New York State
Department of Environmental Conservation (DEC) and the Town’s own engineer expressed
concern over the project’s stormwater plan, as seen in the DEC’s request for updated modeling
and the engineer’s comment that permit approval is ‘not guaranteed.. Please see attached pdf.
This is highly relevant, as stormwater is a direct pathway through which PFAS and microplastics
from synthetic turf enter the environment. These substances are persistent, bioaccumulative, and
harmful to both ecological and human health.
If the Zoning Board is considering any approval or variance related to this project, it must
require that Cornell commit to publicly transparent, independently verified testing on
representative samples. At minimum, this should include:
1. Total Fluorine Testing (TF) using a sensitive method such as Combustion Ion
Chromatography (CIC) establishes whether fluorine is present, a key indicator of PFAS
2. EPA Method 1633 on the same sample, following cryo-milling to capture extractable
PFAS embedded in the plastic
3. Leaching Analysis (EPA Method 1312, SPLP) on the same sample, followed by
LC-MS/MS (1633)
→ Assesses exposure risk via runoff and groundwater
4. Additional cryo-milling testing for polymeric PFAS not included in EPA 1633, such
as PTFE (Teflon) and PVDF (polyvinylidene fluoride), which are commonly used in
synthetic turf systems and are not detectable through conventional PFAS methods
If PFAS is detected in any of these tests, it directly implicates Cornell’s noncompliance with
New York State’s Carpet Collection Program Law (Article 27, Title 33 of the Environmental
Conservation Law), which restricts carpet-like products containing intentionally added PFAS.
Synthetic turf qualifies as a plastic-backed, carpet-like product used for flooring.
Please note that the new carpet law defines “Perfluoroalkyl and polyfluoroalkyl substances or
PFAS substances” broadly as “a class of fluorinated organic chemicals containing at least one
fully fluorinated carbon atom,” a definition that aligns with the OECD’s international standard
(ACS source). Detection of PFAS—using any of the scientifically valid methods described
above—would indicate that Cornell’s proposed turf is not compliant with New York State law
and that their public representations regarding product safety have been misleading.
This is precisely why public oversight is non-negotiable. The testing proposed by Cornell to
date—carried out by or under the control of the manufacturer—is not credible, not transparent,
and not compliant. We need independent, publicly accountable testing to prevent PFAS
contamination and microplastic pollution.
We request that the Town of Ithaca rescind the Negative Declaration issued on March 18,
2025, pursuant to 6 NYCRR § 617.7(f), on the grounds that new information obtained via
FOIL indicates substantial deficiencies in the environmental review—specifically, concerns
raised by the NYS DEC and the Town’s engineer regarding flawed stormwater modeling
and the possibility of permit denial. These concerns were not disclosed or addressed in the
SEQR review, and the Negative Declaration cannot stand in light of this information.
Respectfully submitted,
Yayoi Koizumi
Zero Waste Ithaca
yayoi@zerowasteithaca.org
