Don’t Flood FDR Park

Feel free to directly copy and paste or edit Clean Air Council’s suggested comment below and email it to:

RA-EPWW-SERO@pa.gov

Please also fill out the petition below so Clean Air Council can track your engagement. Please be sure to include your full name, address and phone number in your email to the Pennsylvania Department of Environmental Protection (DEP).

Subject: PAC510333 - FDR Park - Pattison Fields - Pkg #2

Philadelphia Parks and Recreation is currently applying for a stormwater permit to construct over 10 acres of artificial turf playing fields in FDR park, in the location of a former public golf course. Parks and Recreation’s proposal also involves a parking lot, picnic area, and four basketball courts. However, the large set of artificial turf playing fields presents unique issues that could cause flooding in FDR park, which is already located almost entirely within an 100-year floodplain. Parks and Recreation is proposing to use 300,000 cubic yards of soil dredged from the Southern portion of FDR park to elevate the proposed development about 12 feet above sea level. Parks and Recreation proposes to gather the rainwater that lands on the proposed playing fields into a stormwater management system that would discharge water into the Shedbrook Creek, south of the proposal area. Additionally, Parks and Recreation plans to construct a new wetland area south of the proposal that would help manage stormwater discharged from the site. 

The purpose of the current permitting process is to evaluate proposed stormwater management techniques, a task which Parks and Recreation has made impossible by providing none of the necessary detail regarding how stormwater would move through the proposed artificial turf playing fields. Parks and Recreation claims that the specific design of the playing fields will be detailed in the future, but the current approval process must not continue without clear designs for how the proposed playing fields would convey stormwater south of the site. These 10.53 acres of artificial turf playing fields are the single largest individual land use within this entire proposal. The Pennsylvania Department of Environmental Protection (DEP) should require Parks and Recreation to detail the exact stormwater management strategies that would be used within the artificial turf playing fields, specifically including the underdrain system.

Another concern is that laboratory testing, such as that conducted at the University of Massachusetts, Lowell, has found toxic Per- and Poly-fluoroalkyl Substances (PFAS) in artificial turf. Some cities and states have responded by banning PFAS in artificial turf amidst the growing scientific understanding of the long-term damage to human and ecosystem health by these “forever chemicals.” DEP should require Parks and Recreation to either commit to using PFAS-free artificial turf or disclosing that it would contain PFAS. If it would contain PFAS, Parks and Recreation should provide a plan for monitoring and addressing PFAS contamination in the stormwater runoff, and the public should have the opportunity to comment on its plan.

Additionally, although Parks and Recreation has obtained a permit from the DEP to construct a 2.3 acre wetland mitigation south of the site and west of “Half Moon Lagoon”, the habitat assessments associated with the current permit application contradictorily describe this wetland mitigation area as being only “up to .5 acres.” DEP must require Parks and Recreation to resubmit the current stormwater discharge permit application to include the most accurate information regarding the new wetlands that would be required because of the proposed project. Both the exact stormwater management practices that would be used within the artificial turf playing fields and the exact size of the wetland mitigation area proposed to accommodate this development must be fully detailed.