PEER files formal complaint against turf manufacturers

Environmental ethics nonprofit alleges unfair advertising and deceptive marketing.

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"An aerial photo referenced in a complaint to the Federal Trade Commission made by the Public Employees for Environmental Responsibility shows synthetic turf carpets being illegally stockpiled."

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.

8 COMMENTS

  1. they said it would be open in 2019.. More than 2 years later, in Dec of 2021, they say they are planning to renovate a building in P.A , and provide some jobs at some point. They are probably waiting for the “pillow guy” to produce all the evidence he has and get trump back in office. If that happens, they won’t need a building, just a burn pit.
    The whole industry stinks.. My advise to the commission is;
    If you don’t want to smell like what you are about to step in, don’t step in it.

  2. Thank you Lucas for this information. Anyone that did their homework on this industry already knows that the 9 billion dollar turf industry has green washed the realities of their profitable, toxic and temporary product. This industry’s greed has resulted in waste and environment destruction that will outlive us all.
    The instance gratification and “ Friday night lights “, feel good moments are short lived compared to the long term environmental detriment . Let’s move foward with grass fields . The MVC made a terrible error . They apparently did not have the information we have now. They are not scientists, or economists or environmentalist, they are volunteers .

    See below from Nantucket’s Environmental Youth forum
    FF to min 48

    https://m.youtube.com/watch?
    v=_aVRrag13rM

  3. From this article: “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.”

    We have been promised that an “anonymous donor” will install the new synthetic field, if we ever get to that point. We have no idea if they have committed to pay for the other stuff in the Sports Complex: field house, 1000 person stadium, press box, etc. We DO know, however, that the towns have and will pay for the design of all of that (already over $500,000, and growing), permitting, legal fees, maintenance, disposal and replacement, and probably more.

    Just want to remind the finance committees of the island and ALL taxpayers: If this project goes forward, the six town taxpayers are on the hook to pay for the “prohibitive” cost of shipping the old turf to the Netherlands when it fails, probably in about 10 years.

    The general laws of the state of Massachusetts impose on all town finance committees in the Commonwealth the responsibility to be the watchdog of spending required of their taxpayers on “any or all municipal questions for the purpose of making reports or recommendations to the town.” Finance Committees of the island: Do your damn job.

    • Ms Divoli, as an elected official for the town of Chilmark I expect more of you,  I expect you to FACT check before commenting. How disappointing, especially in matters for which you are elected (finances).
      It was made very clear during the MVC public hearings and is in the record easy to fact check:
      The matter of donors , would be taken up after the permitting process was complete which it is not and so no commitments from donors exist yet and the fact you say you have no idea if they’ve committed to pay for the other “stuff” the Martha’s Vineyard Commission very clearly states in condition 1.1 “all project costs must be covered by donations prior to the award of the construction contract”
      Not sure how you can have NO idea when that’s explicitly stated all donated money  has to be in hand for ALL of Phase one before going out to bid !

      Shame on you for incorrectly stating that the tax payers would be on the hook for recycling costs. Again the MVC clearly states in the  condition 6.2
      “ The entire cost of packing and shipping and recycling shall be covered by the manufacturer” It was made clear this would be in a bond that the school would have a in hand from the manufacturer to cover these costs.

      I suggest YOU do your  job and get your facts straight before looking down your nose at fellow Fincom elected officials .

      To the general public you can fact check  easily on the MVC website :under the heading:Previous Staff Notes  :find this link can find answers to questions listed by topic : https://www.mvcommission.org/sites/default/files/docs/MVRHS%20questions%20by%20topic%203-31-21.pdf

      This misrepresentation to persuade really just needs to stop 🛑.

  4. MV has a sole source aquifer. One large puddle of water which we all drink from. Why on earth would we take any chances that could screw it up?

    Micro plastics are a major problem everywhere and MV needs to think bigger than whether this is unfair to athletes.

    We are talking the long-term health and future of Martha’s Vineyard. We cannot afford to take chances

    • Have you checked what land mass covers the sole source aquifer? That would be the entire island! Not just the high school property. All septic systems. All golf courses. All transfer facilities. The airport. All auto repair facilities. The nice aging turf tennis courts up island. The nice lawyer’s turf putting green on West Chop. They all are part of the recharge of the aquifer. Beating the drum for this is admirable. But maybe stop all new septic systems first. They are much more dangerous and all boards of health know this.

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