Testimony Regarding Recycling of Artificial Turf
October 9, 2020
To: Martha’s Vineyard Commission
Oak Bluffs Planning Board
From: Amanda Farber, Safe Healthy Playing Fields, Inc
To All It May Concern:
There is a concerning lack of clear answers, no meaningful regulations or independent accountability, and a history of unsubstantiated claims by the artificial turf industry regarding “recycling” of the component materials that make up their product.
In light of this, the claims being presented regarding the potential to “recycle” the artificial turf field proposed for Martha’s Vineyard must be very carefully reviewed.
RECENT NEWS ARTICLES
A number of recent news outlets have covered the growing problems associated with the end of life disposal, and challenging “recycling” issues, surrounding artificial turf:
- The Atlantic - Fields of Waste: Artificial Turf Is Piling Up With No Recycling Fix; December 19, 2019. https://www.theatlantic.com/science/archive/2019/12/artificial-turf-fields-are-piling-no-recycling-fix/603874/
- York Daily Record / USA Today - Worn Out Artificial Turf Fields Pose Huge Waste Problem Across Nation ; November 18, 2019
https://www.ydr.com/in-depth/news/2019/11/18/old-artificial-turf-fields-pose-huge-waste-problem-environmental-concerns-across-nation/2314353001/
- Seattle Times - Feds Order Owner of Dam on Puyallup River to Clean Up Spill From Artificial Turf; September 3, 2020 https://www.seattletimes.com/seattle-news/environment/feds-order-owner-of-dam-on-puyallup-river-to-clean-up-spill-from-artificial-turf/
BACKGROUND INDUSTRY INFORMATION
All artificial turf fields have limited lifespans and require regular replacement at least every 8-10 years. Some organizations and jurisdictions have fields that have required more frequent replacement.
Between the large number of artificial turf fields that must be removed every year, the petrochemical based plastic carpet, the shock pad, and the infill component of each field (consisting of silica sand, scrap tire waste and/or other alternative infill), this represents a massive amount of material which must be managed.
The Synthetic Turf Council (STC), the “world’s largest organization representing the synthetic turf industry,” released their latest version of their Guideline to Recycle, Reuse, Repurpose and Remove
Synthetic Turf Systems in 2017.
https://cdn.ymaws.com/www.syntheticturfcouncil.org/resource/resmgr/guidelines/STC_Guideline_for_Recycle_Re.pdf
The guide describes the many challenges associated with artificial turf recycling, stating that the amount of material to be handled is “enormous,” but the guide offers very little in the way of specifics or actual answers. The STC guidelines admit, “The diversity of such component materials [in artificial turf] presents technical, economic and logistical challenges unlike other commonly recycled materials, such as plastic bottles, carpet and plastic bags.”
In fact, there has also been extensive and enlightening recent reporting regarding the difficult technical, economic, logistical and environmental costs of recycling even those products which were generally considered “easier” to recycle; and again, plastic artificial turf is considered much more notoriously difficult to actually recycle into a viable post consumer product. In addition, the oil and gas industry is continuing a push to build additional facilities to provide the petrochemicals needed to create new plastic products including artificial turf:
- NPR / PBS Frontline - Plastic Wars: Industry Spent Millions Selling Recycling — To Sell More Plastic; March 31, 2020 https://www.npr.org/2020/03/31/822597631/plastic-wars-three-takeaways-from-the-fight-over-the-future-of-plastics
- Bloomberg - A Plastics Giant That Pollutes Too Much for Taiwan Is Turning to America; December 12, 2019 - https://www.bloomberg.com/news/articles/2019-12-12/asian-company-that-pollutes-too-much-at-home-expands-in-america
- Yale University - The Plastics Pipeline: A Surge of New Production Is on the Way ; December 19, 2019
https://e360.yale.edu/features/the-plastics-pipeline-a-surge-of-new-production-is-on-the-way
The STC guidelines also state that, “The cost of shipping is one of the biggest challenges associated with synthetic turf reclamation. Logistics, timing and the possible cost of testing the material to recycle and reuse may need to be considered….The carbon footprint of a particular option (such as trucking at long distances) may be integrated into the decision-making process and lead responsible parties to invalidate such a specific option and look towards others.”
The industry often uses vague or greenwashed language with regards to recycling. For example, just
because an item is theoretically “recyclable” does not mean it is practical to do so. In addition, the term “recycling” is often used when in fact companies are referring to “reusing” or “repurposing.” This can mean removing used (sometimes heavily deteriorated) plastic fields and laying the turf down elsewhere where it has the potential to continue to pollute. And then where does the material go after that? The industry often vaguely refers to products made from recycled turf, but has offered little in the way of proof of those products in a transparent manner or on a scale that is practical and viable.
We do know there are currently no complete circular artificial turf recycling facilities in the United States at this time. Artificial turf often ends up landfilled, incinerated, dumped, or stockpiled. There are documented and reported stockpiles throughout the United States.
One of the largest artificial turf companies, Fieldturf, previously claimed to have a guaranteed “Take-Back” program, which they no longer actively advertise. Despite being repeatedly asked, nobody in the company could answer questions about how many artificial turf fields they “took back” and what actually happened to the material.
Also of note, despite using the term “recyclable” in marketing materials, the artificial turf industry has fought against extended producer recycling laws and even against basic regulations which would require minimal accountability regarding disposal and recycling. For example, at the Maryland State legislature in 2019 and 2020, representatives from the Synthetic Turf Council, Fieldturf, and several scrap tire industry associations testified against bills which would have required greater transparency about industry disposal practices, and which would have promoted extended producer responsibility, rather than having the burden of disposal weigh fully on individual jurisdictions, school systems, and organizations.
When Mr. Dan Bond, President of the Synthetic Turf Council was directly asked at the Maryland State Legislature hearing in March 2019 if there were any artificial turf recycling facilities in the region, he answered that he would have to “look at their member list,” but that he knew of one facility in Denmark (referring to ReMatch; clearly not in the United States).
At another hearing in February 2020, Mr. Bond again testified and again was not able to provide information regarding artificial turf recycling facilities in North America. At that hearing Mr. Bond
claimed to have information regarding a company called Target Technologies International Inc (a member of the STC) which will ship the plastic field component (not infill) to an undisclosed location in Malaysia, even though in prior conversations Mr. Bond claimed he was not aware of specifics of that company’s recycling program. Following the hearing Mr. Bond did not provide promised answers to basic follow-up questions.
TIMELINE AND INFORMATION REGARDING RECYCLING CLAIMS FOR MARTHA’S VINEYARD PROJECT
A number of reports and communications regarding the Martha’s Vineyard High School project have raised the issue of end of life disposal of artificial turf. The following timeline contains information provided to the jurisdiction and other stakeholders about the potential recycling process and location. Several of the claims made have been contradictory and raise further questions.
- April 4, 2016 - Bill Seymour of Gale Associates, the design firm hired by MV@Play, presented to the MVRHS school committee as part of a prior proposal to install an artificial turf field. In the presentation Mr. Seymour claimed that great strides had been made in the last 48 months to address the end of life issues with artificial turf. He said that although it is expensive, the carpet can be cut, rolled, trucked to Dalton, Georgia, and then ground, pelletized and re-extruded as lawn furniture and other things. He shared a photo of a beer coaster he claimed was made from recycled plastic carpet.
Despite the above claim, there was no additional information or established evidence provided (such as name or address) of an artificial turf recycling facility in Dalton, GA in 2016 (or at the present time).
- February 4, 2019 - The Final Report from Huntress Associates for Martha’s Vineyard High School
Athletic Field Master Plan stated: “The ability to recycle an entire synthetic turf field, at little to no cost to the owner, is now possible. HAI recommends that MVRHS explore the possibility of requiring that their turf go to a recycling facility at the end of its useful life. This process should be documented through proper chain of custody certification to insure the products do not get re-purposed or end up in a landfill. One such recycling facility is presently being constructed in Pennsylvania by ReMatch Turf Recycling, Inc., and is expected to be fully operational by 2019.”
- April 24, 2019 - A MV Times article by Matthew D'Andrea stated: “By partnering with ReMatch Turf Recycling , we will take the necessary steps to ensure that the synthetic carpet is recycled and does not end up in a landfill.”
- August 13, 2020 - Horsley Witten Group, Environmental Performance Review project report: “There is currently no facility that can provide a practical alternative for end-of-life recycling. While the Greenfields promotional materials claim that the USA MX Elite Woven synthetic turf carpet is fully recyclable, the applicant has not demonstrated the practicality of recycling the materials that are proposed at MVRHS. Objective 4 of the Master Plan is to “Draft a specification that requires end-of-life recycling, including chain of custody certification for all products' (page 16), but only presents a single option for recycling facility to be operated by ReMatch Turf Recycling in Pennsylvania. Horsley Witten was unable to confirm that this facility will be open in the next few years or confirm the availability of any other such accessible recycling plant. This does not preclude the opening of a facility in the next 7-10 years, which is the likely lifespan, depending on several factors. If there are other options for recycling or reuse, the applicant should provide alternative plans or more evidence of successful synthetic field recycling in the area."
According to ReMatch CEO Dennis Anderson, there was no ReMatch Turf Recycling facility actively under construction or operational in Pennsylvania at the time of the Huntress report, as documented in an email sent to Public Employees for Environmental Responsibility on September 25, 2019.
https://www.peer.org/wp-content/uploads/2020/01/1_30_20_Re-Match_email.pdf
This was again confirmed in communications with a MV Times reporter as reported on February 4, 2020.
https://www.mvtimes.com/2020/02/04/questions-raised-mvrhs-field-project/
Additional claims were then made regarding a different company, Greenfields/GBN-AGR.
- February 4, 2020 - In a letter to the Martha’s Vineyard Commission, Mr. Joe Fields, President of
Tencate Grass / Greenfields Turf stated: “We can guarantee that any synthetic turf field that is installed at Martha’s Vineyard can be recycled through our process at our new joint venture plant in the Netherlands and we are willing to provide chain-of-custody documentation at the time of removal. Furthermore, we are in the planning stages for a similar recycling facility in the US and we are confident that our US-based recycling facility will be online in the next 24 months.”...“Being located at the port enables us to receive turf from virtually any location in the world.”...“Ironturf is made of components that are part of the polyolefin family and therefore be re-pelletized and put back into the exact same production stream to create the fibers of new synthetic turf fields.”
- May 1, 2020 - In a subsequent letter submitted to the Martha’s Vineyard Commission, Huntress Associates stated: “Additionally, we have been reviewing the questions regarding the end-of-life of the turf products and recycling of the synthetic carpet. We have spoken with representatives of Greenfields USA, who have just opened a turf recycling facility in the Netherlands and are committed to opening another facility in the United States within the next 2 years.”
However additional communications directly with GBN-AGR raised questions about the accuracy of the above stated claims that the material can be shipped to the Netherlands for processing, that there is a GBN-AGR artificial turf recycling facility which will be online in the near future in the US, and that the plastic material is circularly recycled into the fibers for new fields.
- May 11, 2020 - An email dated from Carmen Hemel of Tencate Grass regarding the Greenfields/GBN-AGR recycling facility in the Netherlands stated: “We expect to be fully operational within a few weeks. Nevertheless, we also see the need to have a fully operational first plant in Amsterdam so we can optimise the process before copying to other locations.”
- September 22, 2020 - Following a phone conversation, a follow-up email from Eric Van Roekel, CEO of GBN-AGR, provided answers to the following three questions:
● When we spoke you had explained that the Amsterdam facility was designed to service a certain geographic area in the Netherlands and would not be accepting used artificial turf shipped from the United States since the logistics and the carbon footprint did not make sense. I wanted to make sure that was still the case? “ We need to do the numbers but I still believe a field from US should be recycled in US and not shipped abroad.”
● At the time you also stated that GBN-AGR had no active plans to build artificial turf recycling facilities in the United States. You indicated the company was focused on the Netherlands for the time being, that people wanted to make sure the system was working first, and that any possible expansion would happen in Europe first. I wanted to confirm that you still do not have any current plans to construct a facility in the United States? “The recycling plant in Amsterdam is up and running. This was an important step for us before expanding the business elsewhere. We say “we walk the talk.” As we speak we are formalizing the plans for new recycling plants in Germany and France. Next step could be US/Canada.”
● Is the facility operational and actively processing the turf now? “The facility in Amsterdam is up and running. The End-of life fields are coming in and new circular products are produced. Sand is reused in new fields, the rubber is used in production of new rubber products and the field is transformed into an RTA (Recycled Turf Agglomorat) and used for sport technical layers and new products.”
- October 5th, 2020 - the Vineyard Community Sports Complex Facebook page tagged the Oak Bluffs Planning Board MV Commission in a post which read: “Did you know that when the MVRHS turf field is past it's lifespan it will be recycled! I love that MV is always setting the standard for environmental concern! Here's one of the world leaders in Synthetic Turf Recycling!
Check out there (sic) page for more info. https://www.re-match.dk .” In addition, a petition from the Vineyard Community Sports Complex claims that “ this project supports the reduction of plastic as it is made from recycled materials and will be recycled!”
Again, at this time there is no ReMatch or GBN-AGR recycling facility operating in the United States. The Synthetic Turf Council has stated that the logistics, cost, and carbon footprint of shipping used artificial turf significant distances can be problematic and needs to be a consideration for projects. Note that despite the presence of the ReMatch facility in Denmark, there are still massive stockpiles of old artificial turf in Europe (see video link below). In addition, there is no independent verification that the artificial turf field proposed for the MVRHS project is actually made from recycled material. It is also unclear what products are actually being produced from the “agglomerate” at this time.
Zembla - The Artificial Turf Mountain ; September 20, 2018
https://www.bnnvara.nl/zembla/artikelen/the-artificial-turf-mountain
In addition to the above timeline, on September 12, 2020, a memorandum summarizing findings from a case study assessment by the Horsley Witten Group (HW) of comparable athletic fields at four high schools in the region indicated: “None of the schools were able to provide information about where and how their field would be recycled or disposed, although some included the field recycling or disposal in the replacement contract.”
CONCLUSION
It should not be this difficult for stakeholders to obtain basic verifiable information regarding real recycling versus rumors of recycling. Real recycling requires a process which is proven, practical, makes sense from a cost perspective and carbon emissions standpoint, and produces a scalable and functional product. Again, all recycling claims for this project must be carefully reviewed.
It is important to note that Martha’s Vineyard is far from the only jurisdiction which has had to try to wade through artificial turf industry recycling claims which may be greenwashed, misleading, or more wishful thinking than reality. The following are only a few examples of instances where disposal and recycling were far from transparent.
ARTIFICIAL TURF RECYCLING CASE STUDIES FROM OTHER JURISDICTIONS
Sharon, Massachusetts - In a meeting on 9/24/2019, the landscape architect consultant, David Warner, from Warner Larson stated there were two artificial turf recycling facilities in the US - the Rematch facility in Pennsylvania (he stated that was the closest facility to Sharon) and another facility in the mid-Atlantic which he could not name. He said there was a great video of the ReMatch facility in Pennsylvania so people didn’t have to visit it. He said artificial turf fields were fully recyclable and that the turf backing was turned into plastic railroad ties for decks and things. When asked by a stakeholder to provide the video showing the Pennsylvania Rematch turf recycling facility referred to at the meeting, he replied that he saw this information during a professional conference last year and did not believe it was available online. We now know a ReMatch facility did not exist in Pennsylvania at that time, and does not exist at the time of this writing.
Rockville, Maryland - Fieldturf guaranteed the Montgomery County Public School district in writing in 2009 that the used artificial turf material from the Richard Montgomery artificial turf field would be “100% recycled after its useful life is finished and will also guarantee that the field does not end up in a landfill." Upon the field’s removal in 2018, a number of questions were raised by local stakeholders about where the material ended up. A company called TurfCycle indicated that the “field was shipped on 7/18/2018 has been accounted for and received by 11011 Pulaski Hwy, White Marsh, MD 21162 storage facility awaiting further re-purposing.” The company’s marketing included the statement, “using the Turf Cycle solution ensures you that the artificial turf is going through the most efficient recycling method available.” In fact, it turns out the old field and infill were laid down at a paintball facility directly next to Bird River at that address. Subsequent photos showed the site to be a mess with discarded stacked rolls and tire crumb waste pollution everywhere. It is unclear where the degraded material will end up after that.
Bethesda, Maryland - Montgomery County Public Schools required the contractor removing the Walter Johnson High School artificial turf field in January 2020 to recycle all of the material including the plastic component and tire waste infill. The field had been significantly shedding plastic “grass” for years leading up to its removal. The contractor employed a subcontractor called Target Technologies International Inc (TTII), who is affiliated with another company called PolyPacific, Inc, to ship ~40,000 pounds of the used plastic rolls to an undisclosed location in Malaysia to be “recycled.” When asked directly, both TTII and PolyPacific refused to disclose the location of the recycling plant. In addition, there are a number of unanswered questions about the post consumer product. The companies were supposed to produce a (partial) chain of custody which is still not available at this time (October 2020). The hundreds of thousands of pounds of old tire crumb and sand were supposed to be transferred to an artificial turf installation at a school in Maine. However, it was discovered that that school did not want the old material. It is now stored at an “undisclosed location.”
Washington, DC - Georgetown Day School replaced their artificial turf field in 2019. The school was told that the old field would be recycled by Playing Surface Solutions, Inc (PSS) in Meadville, Pennsylvania. The school was told “PSS recycles the material by sifting and cleaning the sand and rubber infill for use in other applications. The carpet is broken down, recycled, and repurposed as composite decking, such as Trex.” Note that Trex has specifically said it does not accept artificial turf for recycling as part of their products. There is no independent verification of other plastic lumber companies successfully utilizing artificial turf in their products on a regular practical basis. Even though the school’s contract with Astroturf included a provision for recycling/repurposing the waste so the discarded elements did not end up in a landfill, PSS was clear that they don’t accept the shock pad, and it appears that the used shock pad did in fact end up going to a landfill. The school was also told that PSS had a sister company called Reclaimed Rubber and Plastics (which was listed in the past at the same address as PSS) and that the company would separate the plastic carpet component and infill. It was noted they sometimes sell off rolls of the old plastic carpet to be laid down elsewhere. They also say the “synthetic fibers....are baled and sent to a recycling center for further process to be turned into fuel.” This does not indicate where the “recycling center” is located; and “turned into fuel” means incineration, which is not considered an acceptable form of recycling.
Puyallup River, Washington - Used artificial turf was used for the base of a dam being reconstructed on the Puyallup River in 2020. The material came from a nearby large stockpile of old artificial turf and tire waste which has been growing since 2012 at a nearby rock quarry. Some of this stockpiled material may have come from jurisdictions who were told their old fields would be “recycled,” but there is little information available regarding the chain of custody of old fields. The turf material used for the dam construction came loose and created extensive pollution over 40 miles, threatening to harm the already endangered chinook salmon due to arrive on their homeward journey in a matter of weeks. This is an example of environmentally disastrous reuse and recycling.
https://www.seattletimes.com/seattle-news/environment/rubber-debris-litters-miles-of-puyallup-riverafter-artificial-turf-was-used-in-dam-project-without-permit/
Cleona, Pennsylvania - In 2019 a large pile of old artificial turf was reported on an industrial lot in Cleona. The mayor of the town, Mr. Minnick “said there had been plans to build a plant in Lebanon County to process the rubber backing into a material to be used to make tires. The artificial grass blades, he said, would have been used for fuel. But the plant was never built. The company who brought truckloads of the artificial turf to Cleona is contemplating either trucking the hill of turf to another plant in the United States or shipping it to Belgium or Denmark.” Note again, that “used for fuel,” means incineration, not recycling. The status of the pile is unclear at this point.
https://www.ldnews.com/story/news/2019/05/07/cleona-council-meeting-disposal-plans-needed-artificial-turf/1130527001/
Beaumont, Texas - Hellas Construction removed an old artificial turf field in 2018. It was supposed to be “hauled off” but instead it was dumped on a lot in Beaumont, TX. It is unclear what ultimately happened to the material.
https://www.beaumontenterprise.com/sports/hs/article/BISD-Old-turf-should-not-have-been-dumpedat-lot-13047369.php
Albemarle County, Virginia - There is a case of illegal dumping of used turf from the University of Virginia. “There were a series of big dump trucks traveling on a dirt road up a nearby mountain. The neighbor told [County Supervisor] Mallek that the unusual amount of traffic had so surprised him that he had finally stopped one of the drivers and chatted him up. The driver told him he was carrying used turf from the university but that it was OK, Virginia's Department of Environmental Quality had approved it. This seemed unusual to Ann [Malleck]; she wasn't aware of any legal rubbish dumps up that particular mountain. So she called the university. Her contact there reassured her that DEQ had approved. Then she called DEQ, who knew nothing about it. It was an illegal rubbish dump set up by an enterprising landowner to receive the turf. After formal notice of violation from Albemarle County, the landowner had the turf hauled away, but a couple of months later it was discovered again, by accident, having merely been shifted to another site on the mountain beside a stream. The County had to get involved again and this time the turf was finally taken to a landfill capable of handling hazardous waste.”
https://www.ehn.org/hidden-gotcha-in-artificial-turf-installations-2641507579.html