Nantucket Land & Water Council On Article 12

To the editor: The Nantucket Land & Water Council (NLWC) offers the following comments to provide additional context on several key points regarding the proposed artificial turf field and track in Article 12.

We recognize that our community has many important needs, including investing in our students and athletic facilities. We also have a collective responsibility to ensure that projects of this scale that are located within our public wellhead recharge district, do not compromise the long-term health of our drinking water.

Managed Nutrients vs Forever Chemicals
The NLWC has long championed responsible fertilizer use on Nantucket. We assisted in the development of the town’s Best Management Practices (BMPs) and continue to advocate for thoughtful regulation and public education around nutrient management. We have consistently advocated to curb unnecessary or excessive use island-wide because of the risks these inputs can pose to our ecosystems and public health.

Conventional management of grass playing fields can require significant irrigation, fertilizer use, and chemical inputs. However, there are decades of research, established standards, and practical experience to guide how nutrient inputs to natural grass fields can be minimized and managed responsibly.

In contrast, per- and polyfluoroalkyl substances (PFAS) present a fundamentally different challenge. They are persistent, difficult to remediate, and not yet governed by a comparable body of established, field-specific management practices. While risks associated with fertilizer use can be mitigated through existing science, ongoing management, and oversight, the long-term behavior and cumulative impacts of PFAS in a sensitive landscape remain uncertain.

The Limitations of EPA Method 1633
Our request for comprehensive testing is not a dismissal of EPA Method 1633. In fact, EPA 1633A is indeed a major part of our request. However, there are currently no established standards governing PFAS in manufactured turf materials. Scientific understanding of long-term environmental behavior and cumulative impacts over time remains incomplete and evolving. That is why we are looking at not only what the track and turf materials currently contain, but also what they eventually become when exposed to physical wear, acid rain, and ultraviolet light. These are conditions these surfaces will face on Nantucket, and this is not a unique approach. In fact, there are other entities that have produced guides on testing athletic facilities for PFAS this way, such as UMass Lowell’s 2024 PFAS Testing Guide for Municipalities, which we have utilized in developing our requested standards. In addition to 1633A, leachability testing and analyses that account for precursor PFAS compounds are critical for groundwater protection.

Cumulative Risk and the Zone II Aquifer
PFAS is already present in the environment, including within existing soils and groundwater, building materials, and common industries such as car washes. That underscores the need to limit additional inputs wherever possible, especially in a wellhead protection area. Without complete and consistent testing across all materials, it is not possible to determine whether contributions of contaminants from this project would be minimal or meaningful. Given the persistence and cumulative nature of PFAS, we should avoid introducing new sources unless and until they are fully understood.

The Need for a Complete Analysis of Alternatives
Our community is being asked to vote on one system: synthetic turf, without the benefit of a side-by-side analysis of the natural grass alternative. There are risks and benefits associated with any track-and-field combination. Natural grass is being dismissed as not viable or feasible without a clear evaluation to support that conclusion.

The NLWC’s position remains steadfast. We have been calling for a clear and comparable analysis of all options, natural or synthetic. Which options can fulfill our needs and which option carries less risk? The absence of this analysis impedes the community’s ability to make an informed decision. We have therefore been advocating for a testing regimen for all proposed materials that meets agreed-upon, enforceable standards that minimize risk to our drinking water to the greatest extent possible, and for some basic monitoring of water directly leaching through these materials into the surrounding soils and groundwater. This is what we are asking for in an effort to increase our awareness and understanding, and to minimize our community’s risk.

We must all work to ensure that there is adequate information and safeguards necessary to meet our community needs while protecting the health of Nantucket’s environment and residents for generations to come.

Emily Molden
Executive Director, Nantucket Land & Water Council