The Public Employees for Environmental Responsibility (PEER) nonprofit collective has issued a complaint against artificial turf manufacturers, alleging they violated the Federal Trade Commission Act by using unfair and deceptive marketing practices.
For the past several years, the Martha’s Vineyard Regional High School has been working to completely revamp its athletic campus with new grass fields, a new running track, and a synthetic turf stadium field. The first phase of the project passed the Martha’s Vineyard Commission (MVC) after countless hours of testimony (both expert and public) and deliberation by commissioners; it’s now under special permit review by the Oak Bluffs planning board. The synthetic turf element continues to draw immense debate, particularly as per- and poly-fluoralalkyl substances (PFAS) emerge as deleterious environmental contaminants. A field study by independent environmental consulting firms Tetra Tech and Horsley Witten revealed negligible levels of PFAS in certain synthetic turf components, although it was stressed in the final MVC report that many PFAS are still yet to be classified or identified by the federal government.
In a 31-page report, PEER requested that the Federal Trade Commision investigate the vendors, manufacturers, and marketers of artificial turf. “Our review of numerous websites advertising artificial turf and statements made to consumers shows at least one type of deceptive or unfair marketing common among these businesses,” the PEER report states.
These companies include Synlawn, TurfCycle, Playing Surface Solutions, Inc., and TenCate (one company included in the high school plan). According to its website, PEER engages in advocacy, research, education, and litigation relating to the promotion of public understanding and debate concerning key current public policy issues.
The report lists examples of false or misleading statements having to do with the recyclability of artificial turf, and the ability to use recycled synthetic turf to create new products.
As The Times reported in 2020, no active facility in the U.S. can recycle artificial turf, and the only two facilities known to have this ability are in Denmark and the Netherlands.
Despite a specification in the MVRHS Master Plan that requires end-of-life recycling for a synthetic field, “including chain of custody certification for all products,” and promises of recyclability from field designer Huntress Associates and school officials, the future of any kind of synthetic turf recycling is unclear.
“The ability to recycle an entire synthetic turf field, at little to no cost to the owner, is now possible,” the Master Plan reads. “One such recycling facility is presently being constructed in Pennsylvania by Re-Match Turf Recycling, Inc., and is expected to be fully operational by 2019.”
In a conversation with Re-Match owner Dennis Anderson, The Times confirmed at that time that there was no such facility.
Investigative reporting by The Times is referenced in the PEER complaint, showing the discrepancies between claims of recyclability made by Huntress and comments made to The Times by Anderson.
There are several technical, economic, and logistical challenges involved with recycling artificial turf. According to the PEER report, artificial turf vendors have asserted that fields that reach the end of their useful life have been processed at domestic facilities, but those claims have proved to be specious. The synthetic products that make up these fields, according to the report, “are instead sent to a landfill, incinerated, stockpiled, or illegally dumped.”
Due to the mix of synthetic products that layer an artificial turf field, the report states, recyclability is limited, as products must first be separated and subjected to different recycling processes depending on the material. According to the Code of Federal Regulations that governs recyclability claims, “a product or package should not be marketed as recyclable unless it can be collected, separated, or otherwise recovered from the waste stream through an established recycling program for reuse or use in manufacturing or assembling another item.”
An instance of stockpiling rolls of old synthetic turf carpet is documented in the report. During a follow-up inspection of a Grantville, Pa., property in 2021, spurred by a complaint of improper disposal, a solid waste specialist with the Pennsylvania Department of Environmental Protection identified more than 1,000 artificial turf rolls being stored there.
During an interview, the property owner told the specialist that he had allowed Re-Match, the turf recycling company cited in the MVRHS Master Plan, to utilize the property for storage. As a result of that and subsequent inspections of the property, the Pennsylvania DEP determined that Re-Match had violated several areas of the Pennsylvania Solid Waste Management Act. Some violations related to the failure to receive permits from the DEP, while others surrounded environmental restrictions for waste disposal.
Even if old synthetic turf is able to be shipped overseas to existing recycling facilities, the financial and environmental cost of doing so would prove prohibitive. In February 2020, a letter to the MVC from Joe Fields, president of Greenfields Turf, a subsidiary of TenCate Grass, offered a guarantee of chain of custody documentation and a comprehensive recycling program using an existing recycling facility in the Netherlands, operated by GBN Artificial Grass Recycling.
“We are in the planning stages for a similar recycling facility in the U.S., and we are confident that our U.S.-based recycling facility will be online in the next 24 months,” the letter states.
But correspondence referenced in a letter to the MVC from Amanda Farber of Safe Healthy Playing Fields Inc., quotes Eric Van Roekel, CEO of GBN, suggesting that it would be infeasible for a synthetic turf field to be shipped to the Netherlands. “We need to do the numbers, but I still believe a field from the U.S. should be recycled in the U.S. and not shipped abroad,” the correspondence reads.