The LRWP is opposed to conversion of Thomas A. Edison Park from free public land to fee-based access, and has serious concerns regarding the environmental impact of the proposed project (see our comments below). We encourage watershed residents to review and comment on the Environmental Assessment submitted by Middlesex County to the National Park Service regarding the County’s plan to turn Thomas A. Edison Park into a Destination Athletic Complex with 14 artificial turf fields. You will find the Environmental Assessment and details to provide comment here. The comment period ends on September 3, 2024.

TO: Diane Keith, NER Program Manager / National Park Service / Federal Lands to Parks / c/o 54 Portsmouth St. / Concord, NH 03301

RE: Thomas A. Edison Park Environmental Assessment

On behalf of the Lower Raritan Watershed Partnership (LRWP), I am writing to express objection to Middlesex County’s proposed change of the purpose and use of acreage within Thomas A. Edison Park in Edison Township. The LRWP has reviewed the Environmental Assessment for this project, and remains concerned by the plans to: 1) convert significant contiguous woodland acreage to active park facilities, which will have the effect of further compromising habitat connectivity for wetlands species in a fringe ecosystem area; and 2) replace current woodland and natural grass acreage with artificial/synthetic turf, which will have the effect of eliminating important ecosystem services of filtering stormwater runoff and moderating temperatures provided by these landscapes. Clearly both woodland conversion and installation of synthetic turf will also have the result of exacerbating climate change and pollutant flows in the watershed.

Below we provide more detail on our concerns related to this project:

Failure to account for flood risk

Current flood models suggest that significant portions of the area of concern will be under water in the future. Development of these lands, especially using synthetic turf, will significantly compromise passive floodwater containment in an already flood-prone area of the Lower Raritan Watershed.

Synthetic Turf Sheds Microplastics, PFAS, and Other Chemicals

Like all plastic materials, synthetic turf doesn’t last forever—instead, it breaks up and sheds massive amounts of tiny plastic particles into the environment and our bodies. A 2018 report by the European Commission showed that athletic fields composed of synthetic turf shed an annual average of 18,000-70,000 tons of microplastics each year into surrounding air, soils, and waters. This includes huge quantities of crumb rubber, which leaches toxic lead, PFAS, phthalates, and other dangerous chemicals. People and other animals who walk and play on synthetic turf absorb plastic particles and their toxins through the skin, inhalation, and ingestion.

Synthetic Turf Wastes and Contaminates Water

Synthetic turf still requires regular watering, especially on hot days where it can heat up to 40-70 times hotter than the surrounding air—getting even hotter than asphalt. This is because unlike real organic, cooling, and oxygenating grass, synthetic turf is heat absorbent. The temperatures of plastic grass can get so hot it has been known to cause contact injuries called “turf burn.” Heated synthetic turf has also been found to release toxic gases, including carcinogenic benzene and formaldehyde. In addition, materials experts report major drainage issues linked to plastic grass. These issues worsen droughts by preventing groundwater—which many people depend on for drinking—from naturally recharging. When rain falls onto synthetic turf, research shows it absorbs chemicals and runs off—typically entering stormwater systems that drain to large water bodies, in this case the proximate Raritan River and the NY/NJ Harbor Estuary. Also of concern is the increased temperature of the stormwater runoff as it flows into the Raritan.

Increase in Impervious Cover

The conversion of forested habitat to plastic turf and parking lots will increase impervious cover, compromising any attempts to meet federal MS4 requirements let alone advance stormwater management best practices. As we face increasing risks and uncertainties of climate change we should, as a basic practice, never convert parkland to parking lots or synthetic surfaces.

Exacerbates Inequities of Access to Recreational Spaces

The Federal Government deeded Thomas Edison Park to Middlesex County to be used as a free park in perpetuity. Conversion of these free public lands to fee-based access violates the original intent of the deed, and the public interest. Furthermore, the County proposal is for expansion of park amenities in an already well-resourced portion of Middlesex County. The County clearly has not taken transportation equity or other equity concerns into consideration with respect to improving equitable recreational access to County system parks for low socio-economic status communities and for communities with limited access to transportation to park networks.

The LRWP respectfully requests that the National Park Service deny approval to Middlesex County for the proposed changes to Thomas Edison Park.

Sincerely,

Heather Fenyk, Ph.D., AICP/PP / Board President