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Upper Perkiomen Regional Stream Upgrade Petition

3/19/14 UPDATE

DEP presented their final report and recommendation (no change) to the EQB on March 18th.  Delaware Riverkeeper Network, Perkiomen Trout Unlimited and Lower Milford presented testimony and photos of the Upper Perkiomen region in support of the petition.  The DEP’s recommendation of no change in the designation of the Upper Perkiomen was approved by the EQB after a long discussion with much questions and answers from the petitioners, the DEP, and the Board. The petition is now closed. However, the extensive advocacy (by co-petitioners, local municipalities, member organizations of the Campaign for Clean Water, and other allies) at the EQB level met with some success and was evidenced in the close questioning of DEP during the meeting.  The petitioners also garnered strong support and letters from legislators including Sen Bob Mensch, Rep Greg Vitali (who sits on the EQB), Senator Pat Brown, Rep Kessler, Rep Simmons, and Rep Toepel.  (Senator Wonderling – no longer in office also supported the petition).   Importantly, an unprecedented waiver of  the two year wait time to submit new data and or a revised new petition was granted.  In addition the petitioners were successful in urging the Fish and Boat Commission to perform trout surveys in the coming months to determine if sections of the upgrade area are deserving of Class A designation. 

On March 18, 2014, co-petitioners including Delaware Riverkeeper Network, Perkiomen Trout Unlimited, and Lower Milford Township presented to the PA Environmental Quality Board in support of the Upper Perkiomen stream upgrade redesignation petition that was submitted in 2008. They highlighted community support for the petition and qualifiers they believe make the Upper Perkiomen deserving of Exceptional Value designation. They also included photos of the region as they presented before the EQB which are part of this presentation.

Upper Perkiomen Petitoner Presentation and Photos at EQB Mtg from Delaware Riverkeeper Network

**2/17/14 UPDATE

Delay helps keep the Upper Perkiomen Petition in Play for Now But Action Could Be Taken to Deny The Perkiomen Exceptional Value Designation as Soon as March 18th if EQB takes it up at Their Next Meeting

On February 11, 2013, DRN received notice from DEP that the Department finalized their draft report on the Upper Perkiomen redesignation petition and was denying all upgrades to all segments of the Upper Perkiomen.  DEP planned to present their final report to the EQB for the Upper Perkiomen petition at the Feb 18th EQB meeting.   DRN and co-petitioners submitted extensive comments  in November last year urging DEP to consider more data and information submitted before killing the Upper Perkiomen upgrade petition.   Despite comments from DRN and co-petitioners, Lower Milford Township, letters from Rep Simmons and Senator Mensch and over 80 letters in support of the petition submitted, DEP finalized their draft report (below) which denied any upgrades to the Upper Perkiomen – leaving all designations as status quo.  And DEP gave DRN only seven days notice that they were presenting their report to the Environmental Quality Board at the Feb 18th, 2013 meeting in Harrisburg to move the petition one step closer to failure.

But the Upper Perkiomen got a last minute reprieve on Feb 17th after requests from Rep. Greg Vitali (who sits on the EQB) DRN, Trout Unlimited, and other co-petitioners requested DEP Secretary Chris Abruzzo and Chair to the EQB remove the Upper Perkiomen from the EQB agenda on Feb 18th.  Hearing us, Secretary Abbruzzo contacted DRN on the Presidents Day Holiday and tabled the Upper Perkiomen agenda item for the time being.  But the next time the EQB could take the petition up could be as soon as March 18th at the next regularly scheduled EQB Meeting so continued pressure to reverse this decision is needed and continuing by DRN and others who want to see the Upper Perkiomen upgraded to Exceptional Value. We are urging the EQB to give us more time to collect additional data and information and to urge the EQB that if DEP brings the petition to the Board, EQB members request DEP hold off on finalizing the petition and encourage more data collection and review and consideration of co-petitioner information that was submitted.  


Perkiomen Creek Current.jpgDiagram shows the current segmented designated uses for the Upper Perkiomen Basin.  Green Lane Reservoir is a major drinking water source for the surrounding region. 

History:

Stream data collected by Delaware Riverkeeper Network and Stroud Water Research Center indicate that the Upper Perkiomen Watershed located in parts of Montgomery, Lehigh, Berks and Bucks Counties is deserving of higher protections.   In light of the exceptional quality of the Upper Perkiomen Watershed and the national and regional significance of this watershed, in December 2007, Delaware Riverkeeper Network and its partners submitted a 43-page petition along with stream data and Appendices to the PA DEP to request an upgrade of the Upper Perkiomen Watershed to Exceptional Value and the Macoby Creek to High Quality.  This regional upgrade, if granted by PA DEP, would better protect the quality of these streams which flow into Green Lane Reservoir and provide drinking water to many Montgomery County residents.  The Exceptional Value designation would more accurately reflect the current importance and quality of the Upper Perkiomen Basin.  

In February, 2008, Delaware Riverkeeper Network, Perkiomen Watershed Conservancy, and Perkiomen Valley Trout Unlimited presented new findings in support of the Upper Perkiomen Creek before the Environmental Quality Board (EQB) in Harrisburg and provided additional co-petitioners and supporters of the upgrade petition.  At this meeting, PA DEP recommended the petition be considered and the EQB voted unanimously to accept the petition for consideration.  Stream surveys by PA DEP will be the next phase of this upgrade process.  
 
Since that time, several supplemental packages have been provided to PA DEP to support the petition.  On Sept 18, 2013, PA DEP provided public notice that the PA DEP draft report for the petition was out for a 30-day public comment.  Unfortunately , PA DEP is recommending that the Upper Perkiomen NOT receive EV designation and instead remain at its current designated uses for all reaches of the Upper Perkiomen (see maps below for proposed upgrade and current designations).  Delaware Riverkeeper Network and its co-petitioners are urging DEP to reconsider their decision and provide a longer comment period for the petitioners to reply and respond. 

With public input for a longer extension, PA DEP extended the public comment period to November 18, 2013 – giving 60 days notice. DRN and our co-petitioners are still urging PA DEP to give us more time and extend the comment so more data gathering can occur. 

Diagram shows the exceptional value designation that DRN and co-petitioners requested for the Upper Perkiomen (in green)  (and High Quality designation for Macoby Creek – in dark blue).

Related

Beaver Creek, Delaware County, PA

Geryville Quarry (Dormant)

Tohickon Creek

Whetstone Run

Upper Delaware Regional Upgrade Petition to PA DEP

Upgrade Petition for the Hosensack Creek

Upper Delaware Regional Upgrade Petition to PA DEP

Overview

The Upper and Middle Delaware River is a jewel for our nation.  It inspires and provides for millions of Americans.  In December 2011, Delaware Riverkeeper Network and our local, regional and national allies submitted a petition to the Pennsylvania Dept of Environmental Protection (PADEP) to upgrade the Upper and Middle Delaware region to Exceptional Value (EV) status.  Based on diverse and healthy water quality, the vast public lands in the region, the importance of the Delaware River as provider of clean water to 15 million Americans, and the incredible ecotourism that this region brings to millions of citizens, this action is needed to give this region the designation it deserves.  

This EV designation is reserved for the state’s cleanest and healthiest streams.  There are only 3,300 miles of streams in Pennsylvania that have EV status and about 23,000 miles that have High Quality (HQ) status.  See an overall map of the proposed upgrade area here

Delaware Riverkeeper Network is seeking input from the community to supplement the data package that we originally submitted in 2011. Do you know of community projects, water protection initiatives restoration projects, protective municipal ordinances or local government actions that have occurred in the Upper Delaware region since 2011?  Please help us gather this information to supplement the petition.  Fill out this quick survey located here to have a community project or initiative included in the petition supplement:  

Related

Beaver Creek, Delaware County, PA

Geryville Quarry (Dormant)

Tohickon Creek

Whetstone Run

Upper Perkiomen Regional Stream Upgrade Petition

Upgrade Petition for the Hosensack Creek

Beaver Creek, Delaware County, PA

Overview

Beaver Creek – Following up on work begun in 2015, DRN continued its advocacy supporting stronger protections for Beaver Creek in Delaware County. This stream flows from Pennsylvania into the Delaware and portions of its landscape are included in the First State National Historical Park. DRN supported the Beaver Creek Conservancy’s 2015 effort to petition for an upgraded designation of Beaver Creek. 

In 2020, the Pennsylvania Department of Environmental Protection (PADEP) released its antidegradation investigation, proposing only a short segment of the stream receive stronger protections (High Quality or “HQ” designation). When the PADEP called for comments on its draft report, DRN secured an extension to the December comment deadline. We are now engaged in mobilizing public comment and we are also advocating for stronger protections (Exceptional Value or “EV” designation) than PADEP is proposing based on the national historical park designation. The comment deadline is February 12, 2021. 

Related

Tohickon Creek

Whetstone Run

Upper Delaware Regional Upgrade Petition to PA DEP

Upper Perkiomen Regional Stream Upgrade Petition

Upgrade Petition for the Hosensack Creek

Upgrade Petition for the Hosensack Creek

Overview

On February 3, 2015, Delaware Riverkeeper Network and co-petitioners submitted a petition to the PA Dept. of Environmental Protection (PA DEP) to upgrade the Hosensack Basin and all of its tributaries to Exceptional Value status. You can view and download the full petition here

The Hosensack Creek, a tributary to the Perkiomen Creek flows through a rich area of forested and preserved country farms with rolling hills and historical features throughout that make it a unique natural region for Lehigh and Montgomery County residents and visitors alike. Within the Hosensack’s waters, reproducing wild brown and brook trout thrive and help indicate this stream deserves a stronger protection than its existing Cold Water Fishery, Migratory Fishery designation. The stream is also host to a diverse macroinvertebrate community and healthy thriving wetlands where endangered and threatened species reside, which makes it an ever more important watershed to protect. 

Graphic with the map and legend

The petition regulatory process is a lengthy one. Delaware Riverkeeper Network is urging the PA DEP to provide existing use EV designation promptly so this watershed can be protected from future potential threats while the stream works its way through the regulatory process. Organizations and individuals can help garner support for this submitted petition by writing a letter to the PA DEP at:

Honorable Patrick McDonnell
Chairperson, Environmental Quality Board
Secretary of Environmental Protection
16th Floor, Rachel Carson State Office Building
400 Market Street, Harrisburg, PA 17101


You can also email RA-EPEQB@pa.gov.  Please be sure to also send a copy of your letter to Delaware Riverkeeper Network as well. 

If you live in the Hosensack Watershed and have photos of the scenic beauty of the watershed, please share them with us. If you have fished the stream and observed trout, let us know that too. You can share photos by sending them to faith@delawareriverkeeper.org. Finally, be sure to contact your elected representatives and urge them to write to PA DEP in support of the redesignation petition to protect the Hosensack Creek and grant it Exceptional Value (EV) status.

Related Issue

Beaver Creek, Delaware County, PA

Geryville Quarry (Dormant)

Tohickon Creek

Whetstone Run

Upper Delaware Regional Upgrade Petition to PA DEP

Upper Perkiomen Regional Stream Upgrade Petition

Geryville Quarry (Dormant)

Editor’s note: This issue is currently dormant. We will continue monitoring the situation and may take up the issue in the future.

Overview

Map graphic showing the site

Geryville Materials, Inc, first submitted an application to the PA Department of Environmental Protection (PA DEP) to operate a noncoal surface mine in Lower Milford Township, Lehigh County in 2008. At that time a stream upgrade petition for the Upper Perkiomen Creek and Macoby Creek, submitted by DRN and partners was being considered. That petition closed with no change in the designations of the Upper Perkiomen Creek and Macoby Creek. However, the Delaware Riverkeeper Network (DRN) subsequently submitted an upgrade petition for the Hosensack Creek watershed. The proposed quarry would be located in this watershed.

As first proposed, this project would have opened a 628.5 acre quarry, impacting three unnamed tributaries to the Hosensack Creek and as well as an unnamed tributary to Macoby Creek. Geryville Materials’ withdrew its 2008 application proposed quarry operation, resubmitting a revised application in 2014. In 2015, Geryville Materials submitted a further revised application that reduced the area to be mined to 127 acres.

On June 3, 2015, the PA DEP held a public hearing in Lower Milford Township to take comments on a proposed quarry, stone crushing operation, and asphalt plant. These facilities would be located along the Hosensack’s cleanest tributaries. Local residents packed the Lower Milford Township Building to express their concerns about the impacts of the quarry and associated facilities on the quality of the environment and quality of life. View video of testimony from that hearing here.

On October 22, 2015, PADEP issued a deficiency letter to Geryville Materials regarding its quarry with a list of 95 deficiencies to be addressed. Among the listed deficiencies were many issues raised by DRN, including some issues that DRN alone appears to have raised. Geryville Materials had 30 days to let PADEP know how long it would take to address the list of deficiencies, but did not do so. The company did ask to meet with PADEP and, after an early 2016 meeting, Geryville Materials was given 14 months to address the list of deficiencies.

In May 2017, Geryville submitted additional materials in response PADEP’s 2015 list of deficiencies, but PADEP noted there were still many remaining deficiencies. PADEP issued a second deficiency letter to Geryville Materials on September 30, 2019. Again, Geryville Materials requested a meeting with PADEP. After a meeting in January 2020, PADEP gave Geryville Materials until June 30, 2020 to address the deficiencies in its application.

On July 29, 2020, Geryville Materials’ communicated to PADEP that it had decided to with draw its application to open a quarry in the Hosensack Creek watershed. On July 31, 2020, PADEP processed Geryville Materials’ request and affirmed that this application is no longer valid.

Geryville Materials has indicated it intends to refile in the future, but this project will be starting from scratch and will need to overcome the same barriers that prevented the project from moving forward previously.

Litigation: Delaware Riverkeeper, et. al. v. US Army Corps of Engineers

Overview

In October 2009, the Army Corps announced a Notice to Proceed with the Delaware Deepening project.  In November 2009, the Delaware Riverkeeper Network led four other citizen environmental organizations – National Wildlife Federation, New Jersey Environmental Federation, Delaware Nature Society, Clean Water Action in Pennsylvania – to file suit in Federal District Court in New Jersey against the Delaware deepening proposal.  DRN and the groups also filed a motion in Delaware District Court to intervene in and support the legal action brought against the deepening by the State of Delaware, including a motion for a preliminary injunction. 

 When the Army Corps announced that it was going to proceed with the Deepening project at this time, it was announcing its arbitrary and capricious intent to violate the Administrative Procedures Act, based on non-compliance with no less than 6 federal environmental and community protection laws as well as state environmental and community protection laws.  
 

In addition to being a flagrant violation of state and federal law, the Notice to Proceed and related action by the Army Corps (supported by Pennsylvania) to move forward with the deepening without needed Delaware and New Jersey permits and approvals is a stripping of state environmental protection authority that cannot be allowed to stand. 

While DRN fully supported (and indeed advocated for) legal challenges by New Jersey and Delaware, DRN did not believe the states’ legal challenges fully represented all of the legal violations, nor did the states represent all the interests that DRN and its partners bring to bear on the issue.   New Jersey’s action was broader than Delaware’s and included more environmental claims to be sure, but neither included the full array of environmental harms that is included in the Delaware Riverkeeper Network litigation, and it is impossible to know how the states will proceed strategically.   Further, DRN represents a holistic view of the watershed and the protection of the River and environments, not based on political boundaries, but on their importance to our members and the citizens of the region.

Responding To a Motion

Responding to a motion for a preliminary injunction filed in the Delaware case the Army Corps was allowed to begin one 12 mile stretch of the project with an injunction imposed on the forward movement of the rest of the project.  That initial work began on March 1, 2010.

The New Jersey Judge denied a request by the Army Corps to transfer the New Jersey case to Delaware and therefore to allow the consolidation of the two cases.  As a result the two District Court cases proceeded on parallel tracks.  RN’s attorneys, on behalf of our coalition of clients, filed motions for summary judgment in both district courts.

Delaware Riverkeeper Network, on October 18, 2010, filed a notice of intent to sue regarding the deepening project and ensuring it does not violate the Endangered Species Act with regards to Atlantic Sturgeon, proposed October 6, 2010 for ESA listing by the National Marine Fisheries Service and identified as at particular risk from the deepening project.  

On November 4th, Judge Joel Pisano of the federal District of New Jersey denied our motion to stay proceedings pending the Army Corps of Engineers’ compliance with its obligations under the National Environmental Policy Act (NEPA) and the Endangered Species Act (ESA) to protect Atlantic sturgeon in the Delaware River. We filed this motion after the National Marine Fisheries Service proposed the Atlantic sturgeon for listing under the Endangered Species Act on October 6, 2010. Judge Pisano ruled that our motion to stay was premature because the Corps needs more time to fulfill its obligations under NEPA and the ESA and that granting the stay would cause economic harm to the Port of Philadelphia. He also stated that granting our motion to stay is unnecessary because the Corps is currently under an injunction issued by Judge Robinson of the federal District of Delaware in our litigation in front of that court, preventing the Corps from proceeding with further dredging. 
 
Notably, however, even prior to Judge Pisano’s ruling, the Corps had already canceled its contract process for the next phase of dredging that was intended to begin on December 1, 2010. We understand that the Corps does not intend to begin further work on the Deepening Project until August 2011, and that it is currently working to fulfill its obligations under the ESA to confer with the National Marine Fisheries Service on the Deepening Project’s impacts on Atlantic sturgeon as well as its obligations under NEPA to consider doing a Supplemental Environmental Impact Statement.

On November 17, 2010, Judge Robinson of the federal district court in Delaware issued  her decision on the parties’  cross-motions for summary judgment, rationalizing the Army Corps’ decision to proceed with a multi-year, multi-million dollar project to deepen the shipping channel by a full five feet as an action to “maintain” navigation. Her decision found for the Corps on all counts and enabled the Corps to avoid all responsibility for complying with environmental review, particularly review under Delaware state law. Simultaneously she also denied our motion to stay based on the Army Corps’ need to comply with the ESA and NEPA to ensure protection for the proposed endangered Atlantic sturgeon in the River. Judge Robinson lifted her injunction against the Deepening Project’s proceeding in all reaches of the River, giving the Army Corps the green light to proceed with its plans to deepen, straighten, and otherwise permanently degrade and alter the River and its habitats.  
 
DRN and our co-plaintiffs will file an appeal with the Third Circuit to challenge Judge Robinson’s decision, particularly her faulty reading of the Clean Water Act’s definition of the Army Corps’ ability to “maintain” navigation. 

On January 13, 2011, Judge Joel A. Pisano, District Judge for the United States District Court District of New Jersey issued his opinion in which he denied the motions for Summary Judgment filed by the State of New Jersey and five environmental organizations, including Delaware Riverkeeper Network.  In his decision, Judge Pisano gave the Army Corps deference for their actions and decisions, and used this as a firm basis upon which to rest his opinion.  The Delaware Riverkeeper Network does not believe this deference is factually or legally warranted and that the judge reached a flawed conclusion. 

Update: 2/1/2011

February 1, 2011, the Delaware Riverkeeper Network, the Delaware Riverkeeper, New Jersey Environmental Federation, Clean Water Action, Delaware Nature Society and National Wildlife Federation filed an appeal to the Third Circuit Court of Appeals of the ruling by Judge Sue Robinson of the U.S. District Court in the District of Delaware. 

Update: 2/16/2011

February 16, 2011, the Delaware Riverkeeper Network, the Delaware Riverkeeper, New Jersey Environmental Federation, Clean Water Action, Delaware Nature Society and National Wildlife Federation filed their appeal to the Third Circuit Court of Appeals of the January 13, 2011 ruling by Judge Joel A. Pisano, U.S. District Court in the District of New Jersey regarding the Delaware deepening project. This appeal is the second one filed by the five environmental organizations. The first appeal was filed on February 1, 2011 and challenged the ruling by Judge Sue Robinson of the U.S. District Court in the District of Delaware. 

Update: 1/18/2012:

Oral argument before the Third Circuit Court of Appeals took place on this date. The organizations await decision.

Outcome:

Sadly the courts sided with the Army Corps of Engineers and have allowed the project to proceed without further environmental assessment or consideration.

 

Salem 4 – New Nuclear Plant Being Pursued for Artificial Island

Overview

For years PSE&G has been seeking approvals from the Nuclear Regulatory Commission to construct a new nuclear power plant on Artificial Island, right next to the two existing nuclear plants:

    Salem Nuclear Generating Station & 
    Hope Creek.

There are many dangers to constructing this new power plant.  It would be constructed on wetlands, in the floodplain, in a reach of river that will be subject to increasing flood risks with the onslaught of sea level rise and climate change.  

The Delaware Riverkeeper Network has proactively opposed NRC licensing.

The US Army Corps of Engineers has sought to enter into a land swap with PSE&G that would give them the lands they need for Salem 4, while giving the Army Corps a new area in Logan Township and Oldmans Township, NJ to construct a confined disposal facility for the dumping of dredge spoils. 

In This Proposed Land Swap:

 the Army Corps would be the recipient of 354 acres of land located in Oldmans Township, Salem County and Logan Township, Gloucester County, NJ; and 
    PSE&G would, in exchange, be the recipient of 631 acres (94 acres of CDF and 537 acres of coastal wetlands) on Artificial Island. 

July 15 the Army Corps issued an Environmental Assessment of the land swap that ignores the reality that it paves the way for construction of Salem 4, and does not well consider the implications of the CDF on New Jersey communities or the River.  See the Delaware Riverkeeper Networks’ comments listed below.

The Delaware Riverkeeper Network wrote its first letter to the Army Corps opposing this idea way back in 2010 when it was still just an idea. Now we are leading the challenge to the idea as the Army Corps begins to work to press it to fruition.

Delaware Riverkeeper Network has remained in opposition to the landswap that would provide the property needed for this project to advance. To date, the land swap did not advance.

In 2020, New Jersey put forth a proposal to build a Windport project on the very same site.  If that project were to advance the landswap would not advance apparently displacing the opportunity for Salem 4.  The Delaware Riverkeeper Network is proud that our opposition to landswap helped to prevent it from advancing and bringing us to a point where the project may be unable to advance due to a lack of the needed proposed site.

Dragon Springs Development – Neversink River Threat

Overview

Dragon Springs Buddhist Inc is proposing to dam a headwater stream, destroy headwater wetlands, discharge poorly-treated wastewater to a Basher Kill trout stream, create acres of impervious cover and runoff, all of which would adversely impact the Basher Kill and the Neversink River. This development has already damaged the aesthetics and quality of the Basher Kill and the Neversink River, impacting fish, mussels and other aquatic life that are both ecologically and recreationally important to the region.  The Basher Kill and Neversink River are important recreational resources supporting highly valued swimming and fishing opportunities for both residents and visitors. 

Photo with areal view of Dragon Springs Buddhist Inc

One of the biggest threatened impacts is the proposal to dam a headwater stream in order to manage stormwater runoff.  An extensive forested headwater wetland with amazing ecological biodiversity and ecosystem function would be lost. 

The proposed wastewater treatment plant would pollute both a local trout stream and the Basher  Kill and the Neversink River, with problems such as excessive nutrients impacting trout and endangered species living in these streams and rivers. 

Threatened and Endangered Species

A number of state and federally listed Threatened and Endangered species are also located on-site or in areas affected by on-site activities. Among the biggest impacts that need to be evaluated are the water quality impacts to the Dwarf Wedgemussel and the Brook Floater, two freshwater mussels whose last remaining strongholds in New York state are here in the Neversink River but whose populations have severely declined already in recent decades.

Photo of the wastewater entering the stream

The Delaware Riverkeeper Network is actively working with concerned residents and local organizations to address this major threat.  Dragon Springs included a Draft Environmental Impact Statement with its proposal, but neither a Supplemental Environmental Impact Statement nor a Final Environmental Impact Statement have been shared.  Scathing testimony at the public hearing from the Delaware Riverkeeper Network and all of our partners and residents has slowed the impacts from this proposal. 

Delaware River and Bay Oil Spill Advisory Committee

Overview

The Delaware Riverkeeper was appointed a member of the Delaware River and Bay Oil Spill Advisory Committee created by federal legislation in response to the Athos I oil spill.  This Federal Advisory Committee, which held its first meeting in December, 2008, was given an 18-month life during which it is charged with identifying recommendations to better protect the Delaware River from oil spill events in terms of prevention, response, recovery and mitigation.  The work load  for participants of this Federal Advisory Committee has been daunting but clearly critical.  There are few voices in the group to ensure that the needs of the River and all those who rely upon the River are given the highest priority.  The Delaware Riverkeeper is a member of both the main committee as well as three of the four subcommittees that it has established.

The Report Remains In Stasis

The Committee’s work was to be completed by April 30, 2010.  Due to opposition to key recommendations brought mainly by the Pennsylvania representative and a lack of voting members showing up for the last meeting the committee was unable to render a final vote on the report.  As a result the report remains in stasis.  Efforts are underway to secure a legislative extension that would allow the report to be revisited and finalized hopefully by the end of 2010.

Artificial Turf

Overview

Communities continue to install an increasing number of artificial turf fields. 

The Delaware Riverkeeper Network receives regular calls for information, assistance and comment letters to help resist these economically costly endeavors that bring a variety of harms to the kids and communities where they are placed.  

Environmental & Human Health Impacts

Our comments and concerns include both the environmental and the human health impacts of Artificial Turf.

Synthetic turf is generally made with rubber from waste tires.  Recycled rubber varies considerably in its chemical composition, even when from the same manufacturer. Hazardous substances found in tires may persist in the environment including polycyclic aromatic hydrocarbons (PAHs), phthalates and certain metals.  These substances may be bioaccumulative, carcinogenic, reprotoxic, mutagenic and/or endocrine disrupting.

Research has demonstrated concerns regarding water qualtiy and toxic affects for aquatic life. 

Direct human exposure to the hazardous substances contained in the rubber in-fill of artificial turf is believed to occur via three pathways:  inhalation, skin contact, and/or ingestion including by children who come into contact with the material.  Each pathway creating its own set of health concerns. 

Excessive heat is a major threat for those that play on artificial turf. High surface temperatures found on artificial turf fields can contribute to physiological stress and cause “serious heat-related illnesses”. Heat stress, heat stroke and burns are all of concern.  

If you are faced with an artificial turf proposal in your watershed community reach out if you think Delaware Riverkeeper Network can be of assistance.  In addition, the fact sheets and comment letters provided below include a wealth of information that can help get you better educated on this important issue and provides key points and information you could borrow for your own local advocacy efforts.