Letter: Hinesburg Citizen Says Final Report on Proposed Turf Field at CVU Is Limited
Resident says CVSD board should not base its decision on the hydrogeologist report.
(Editor’s note: This commentary is based on the final report of Waite Heindel Environmental Management released Monday afternoon. As the district noted in releasing the report, the final report does not differ substantially from the draft report released last Thursday. A copy of the final report is below.)
By William Scott
Hinesburg resident
I have partially reviewed the June 29, 2026, Final Report prepared jointly for the school district board by the firms of Waite Heindel and Sandborn Head. In the executive summary the authors refer to the document as a “limited hydrogeologic and environmental evaluation.” I believe that the limitations are very serious and that they have compromised the report’s evaluation, which is incomplete and insufficient to support its conclusions. This final report should be superseded by a revised final report supported by actual PFAS concentration data and rigorous field studies to determine actual site conditions.
The limitations which I will comment on here are:
The absence of actual data on the PFAS concentration of the proposed artificial turf product and the substitution of incomplete and, in my opinion, irrelevant data from a field in Sweden;
The limited scope of work that does not include the field investigations necessary to determine actual field conditions identified as critical to evaluating the risk of contamination of the drinking water supply; and
Insufficient consideration of factors identified as having the potential to mitigate the risk of potential contamination.
At the core of the analysis is an estimate of the total PFAS concentration in the proposed artificial turf field that is baseless. This report is being used to decide on a real project with serious health, safety and financial consequences. It needs to use the data for the product(s) under consideration that has been independently tested and verified. This no different than testing the properties of the steel and concrete for a bridge.
Proponents of the project have presented the merits of artificial turf fields installed in New England, Vermont and even just down the road in Chittenden County. We have heard the claims that the proposed field will be 100-percent PFAS-free and will absolutely meet the requirements of Vermont law, and yet the calculations in the report are based on the concentration of PFOS (just one of the approximately 15,000 PFAS compounds) in a field in Sweden (see Report, page 10).
This is not a hypothetical evaluation but a real project that requires real facts. The use of literature surveys rather than actual test results to prepare an engineering report on a critical component for the project owner strikes me as absurd. It is even more absurd if this is the process required by the owner.
The estimated total PFAS concentration, defined as equal to the PFOS concentration, is 0.78 µg/kg. Again, this process purports to measure only one PFAS compound and ignores all the rest.
Based on this estimate of 0.78 µg/kg, the report states “We conclude that while PFAS from the AT materials in the proposed field at CVU could be briefly detectable in Hinesburg’s Well 4, it would not reach the current Vermont and federal drinking water standards.”
How can the school district board expect the people of Hinesburg to trust this conclusion based on a calculation using no real data? We do not have to go to the moon to obtain a sample to test. Just have a qualified lab take a sample in the factory, put it in a sealed container and provide a chain of custody report from the sample in the factory to the lab. We are repeatedly told that the proposed artificial turf is PFAS-free and meets all Vermont legal requirements and PFAS limitations. It is time that this be demonstrated with real, independent testing with the results provided to the engineers to prepare a revised final report.
The final report presents evidence of site conditions that potentially present great risk of ground water contamination as well as evidence of conditions that might partially mitigate this risk. Field studies, including test borings, are required to determine actual conditions before final conclusions on the risk of ground water contamination and surface water contamination can be made. The scope of work for the final report should be amended to include a thorough study of site conditions and a revised final report issued.
Upward Gradient Assumption: The upward gradient of the groundwater is described as a “likely presence beneath Field B.” The report states that “The apparent upward gradient beneath Field B suggests it will be difficult for significant amounts of contaminants to penetrate the underlying bedrock aquifer. It states that ground water discharging the site is “… possibly also giving indications of an upward gradient in groundwater in the vicinity of Field B.” It also states that data from well logs “indicate that many of the drilled wells have an upward gradient in the groundwater contained in their fractures.” The report relies on the presence of an upward gradient to protect the aquifer from contamination, but its existence and extent of its location have not been verified by field inspections and drilling.
Depths of Bedrock and Pathways for Migration to Aquifer: The report states that “depths to bedrock vary widely in the vicinity of Field B” and “overburden thicknesses range from essentially zero to more than 100 feet.” It also states that “the potential shallow depth to bedrock under the northeast corner of proposed AT field described above means that there would be a short vertical migration distance downward for potential contaminants from the construction and/or long-term use of this field. The risks posed by these conditions require careful assessment based on documented conditions from field studies.
Assumption of Mitigation from Underlying Silt-Clay Overburden: The report assumes that short vertical migration distances potentially could very likely be mitigated by the apparent low permeability of the underlying silt-clay overburden. This assumption has been challenged by a consultant expert in PFAS contamination and should be fully investigated before a revised final report is prepared.
Conclusion: The report reaches conclusions without having the data and information necessary to support them. These shortcomings must be corrected before any estimates of risk of contamination by PFAS can be made. I suggest that these steps be taken and a Revised Final Report issued.
The PFAS content of any proposed products must be determined by independent testing and the results provided to the engineers and the public before any calculations of the risks of contamination can be accurately and safely made.
The scope of work should be amended to include all field investigations necessary to reach an accurate and reliable assessment of risk and a revised final report issued.
The revised final report should be made available at least three weeks in advance of a public discussion to allow time for review by local officials and consultants prior.
Thank you William.