It’s Official – Dover’s Gone Organic!

Without much fanfare, the Dover City Council voted unanimously on Wednesday, June 24th to award the turf services contract to the same vendor doing our Stonyfield site at Woodman Park School ball field.

This means that all city owned property is now maintained using organic methods.

We are grateful to the staff and Council for taking these important steps to protect public health and the environment.

View the June 24th TurfTreatmentAgendaMaterials2020

Thank You Dover! Implementation

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Open Letter: Known and Unknown PFAS Released From Portsmouth’s New Synthetic Turf Field

In a letter dated July, 5th 2022, analytical chemist Kristen Mello, M.Sc. warns Portsmouth officials about the commissioned testing results “confirming the presence, solubility, and mobility of both identifiable and non-identifiable, man-made, toxic, bioaccumulative PFAS in the artificial turf field component products.”

Ms. Mello points out that, “lacking from this testing, report, and discussion were the leaching protocol (SPLP) and calculations (concentrations propagated out for installation mass and size) that would have given you an idea of how much PFAS has been and will be leaching off the field materials and into the stormwater management system.”

Non Toxic Portsmouth and Testing for Pease founder, Andrea Amico have asked the City to perform further testing to ascertain how much PFAS is coming from the field that drains into Sagamore creek.

In emails exchanged with a member of Non Toxic Portsmouth right after the TRC report was released, the Director of Public Works has said the City has no plans to perform further testing.

As Ms. Mello has further noted in a Portsmouth Facebook group, it’s important to understand that the testing report posted online “revealed PFAS in every component of the artificial turf field, and what’s more, confirmed the presence of UNKNOWN and proprietary PFAS for which there are no public toxicological profiles whatsoever.”

“What’s more, the City did not perform the appropriate leaching protocol or calculations to determine how much of these known and unknown PFAS will leach into stormwater and groundwater.

To herald these fields as “safe” because a player won’t chew them is beyond short sighted, especially for a community so hard hit by PFAS water contamination.

Do you really prefer adding mystery PFAS from Chemours in your water to playing on grass???

How come nobody mentioned that the PFAS they found was documented elsewhere in Chemours discharge water???

Taxpayers don’t deserve to be left on the hook for this.”


View the full letter sent to Mayor McEachern, Portsmouth City Councilors, City Manager, Assistant City Attorney, Director of Public Works, and School Board.

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Multiple PFAS Found in Portsmouth’s “PFAS-free” Synthetic Turf Field

After six months of waiting, a report with the results of independent PFAS testing on all components of the new athletic field near community campus was released by City of Portsmouth, NH consultants, TRC on June 7th 2022.

The testing results showed multiple types of PFAS.

In the carpet sample:

• Perflurooctanesulfonic Acid (PFOS)

• HFPODA (Gen-X) 

• Perfluoropentanoic Acid (PFPeA)

• Perfluorobutanoic Acid (PFBA) 

• PPF Acid (Pentafluoropentionic Acid)

• Perfluorohexanoic Acid (PFHxA) 

• R-EVE

In the shock pad sample:

• Perfluorononanoic acid (PFNA)

• Perfluortridecanoic acid (PFTrDA)

• Perfluoroundecanoic acid (PFUnA)

• Perfluorohexanoic Acid (PFHxA)

• HFPODA (Gen-X)

• PPF Acid (Perfluoropropionic Acid)

• Perfluoroheptanoic Acid (PFHpA)

• R-EVE

In the infill sample:

• PEPA (Perfluoro-2-ethoxypropanoic acid)

• PFO2HxA (Perfluoro (3,5-dioxahexanoic)acid)

• Perfluoropentanoic Acid (PFPeA)

• PMPA (Perfluoro-2-methoxypropanoic acid)

• PFMOAA (Perfluoro-2-methoxyacetic acid)

• PPF Acid (Perfluoropropionic Acid)

As Portsmouth residents and others following the progress of this story may recall, the synthetic turf field sold to the City of Portsmouth was approved on a narrow 5-4 vote and supported by some members of the community based on the fact that it was promised to be “PFAS-free.”

Non Toxic Portsmouth cautioned the City and public from the beginning that there was no evidence to back this claim, and even found that the documentation Weston & Sampson provided from the manufacturers showed that there indeed was PFAS in their product. Despite this, the engineering consultants continued to insist that the field would be “certified PFAS-free” and went out to bid on the project.

After the field was installed and Non Toxic Portsmouth conducted independent testing of brand new samples of the synthetic turf finding a range of 16 ppm – 119 ppm total fluorine, indicative that the product was not “PFAS-free,” the City and their consultants rejected the evidence.

Portsmouth consultants and city staff rejected the total fluorine test results showing PFAS was present in the field components in Fall 2021. The City’s new testing confirms these results were accurate.

It wasn’t until they were shown a recording of an industry consultant admitting that PFAS is “intentionally added” to the plastic carpet during the manufacturing process did they finally move toward conducting independent tests. The Council voted to commission testing in December of 2021.

Now, half a year later, Portsmouth residents are left with an egregious breach of contract, and a 1.6 million dollar field full of a cocktail of known and unknown PFAS with the real potential to leach into Sagamore creek, some of which are above the new EPA health advisory limits.

Some questions we are left with:

Does anyone in the City plan to address the clear breach of contract that has occurred? Taxpayers paid for PFAS-FREE products, and they were not delivered! Is the city planning to hold anyone accountable, or just shrug this off?

Will the City opt to conduct further testing, like a leaching procedure on solid samples of the field that would tell us what comes off of it, and testing of the water going into the stormwater system that drains into Sagamore creek?

The residents of Portsmouth and the Seacoast area deserve better than to have the City and their consultants sweep this toxic, bioaccumulative problem under the plastic carpet.

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Organic Curbside Weed Control Proving Successful

Over the last several seasons, Dover has made some big changes to their curbside weed control program, trying a variety of different approaches to manage weeds on streets, curb lines and sidewalks along 33 miles of city roads.

The current program has evolved into a comprehensive approach that is utilizing several methods to manage vegetation.

The vendor reports that this program is working well.

We asked the City to clarify with the vendor what the “sticking agent” and “thickener” were mentioned in the memo and they reported back that nothing was used this year except for the organic herbicide product.

“We have only used Finalsan and never used Esplenade. (sic) We added vinegar and soybean oil to Finalsan last year to thicken the spray material and it worked great. Finalsan is mixed with water primarily but an ounce of soybean oil and an ounce of vinegar helped the spray mix stick to the plant.”

We are happy to hear that this program is going so well and that only organic compatible methods and products are being used in line with City policy. These practices protect our watershed and the people who live in our city. Our Community Services department is leading the way towards improving the way we care for our infrastructure and setting a great example for the other municipalities on the Seacoast.

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NH DES Water Testing Reveals More PFAS Nearest to Synthetic Turf at PHS – More Testing Requested

In a public letter dated January 23, 2022 submitted to Portsmouth, NH officials and other interested parties, analytical chemist Kristen Mello of Westfield Residents Advocating For Themselves (WRAFT) has commented on water testing performed by the New Hampshire Department of Environmental Services.

Ms. Mello’s comments are on the surface water testing of Sagamore Creek taken at
three different locations on October 21, 2021 by the NH DES MtBE Remediation Bureau.

The samples were taken after DES was contacted by Non Toxic Portsmouth founder Ted Jankowski with concerns about the elevated fluorine levels found in Tom Daubney field at Portsmouth High School.

In her letter, Ms. Mello notes that, “The total PFAS detected in the sample downgradient of Tom Daubney field was roughly double the total PFAS detected in the samples taken at the other two locations.”

She concludes by encouraging further testing.

“The question of whether or not the artificial turf field system components installed at Tom Daubney Field are leaching PFAS and other chemicals into the surrounding ecosystem should be answered before decisions are made regarding an upcoming need for field disposal and replacement.”

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Portsmouth HS Synthetic Field is Unsafe For NFL Players – Why Do Our Kids Deserve Less?

Tom Daubney Field at Portsmouth High School Oct 2021

The latest records requested by Non Toxic Portsmouth reveal that the Gmax or hardness level of Tom Daubney Field far exceed the threshold set by both the University of New Hampshire and the National Football League.

Testing done for the City in October of 2021 showed a Gmax of 199 – just one point below the outdated and dangerous 200 Gmax threshold used by the School District.

According to Diana Zuckerman PhD, President of the National Center for Health Research, “A Gmax score over 200 is considered extremely dangerous, and it is considered by industry to pose a death risk. However, the synthetic turf industry and American Society for Testing and Materials (ASTM), suggest scores should be even lower — below 165 to ensure safety comparable to a grass field.

The Synthetic Turf Council recommends a more protective limit of below 165 Gmax using the F355 scale. The NFL uses a different testing tool (Clegg) with a lower scale and sets their limit at about 100 Gmax and test prior to each game. 135 Clegg = 200 F355.

Natural grass fields typically measure 42 Clegg or 85 F355 units.

Portsmouth School District is taking unacceptable risks with the safety of the players using the synthetic turf field when they use the 200 upper limit set by the U.S. Consumer Products Safety Commission. “The 200 G-MAX level set by the CPSC is intended only to protect field owners from civil liability should horrible injury occur,” according to the STMA.

There is very good reason to question the validity of the upper Gmax limit of 200 in light of advances in research on injury prevention.

This report also averages the numbers. All points on the field must be below the limit, not an average. Children do not fall and hit their heads on averages.

The hardest point measured on the field is 199 Gmax which is well above the more protective upper limit of 165. Had this field been installed at the University of New Hampshire it would have been removed and replaced years ago, the same if it were an NFL field. They both keep field hardness below 165.

Listen to the testimony of Dr. Greg Guyton, orthopedic surgeon to NFL Ravens, regarding safety and playing on post-warranty fields like the one at PHS.  Begin at 1 hour 6 minutes of the video for his 2 minute testimony.

This video on Gmax testing also explains why the 200 cutoff is not adequate, and a result of 165 still needs to be remediated.

Are the brains and bodies of Portsmouth High School athletes deserving of lesser protections than college students and professional athletes?

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Artificial Turf Producers Now Admit Using PFAS

Despite a declaration made in 2019 from the German supplier of artificial turf filaments to manufacturer Field Turf/Tarkett Sports that promised their products are fluorine and PFAS free, Morton Extrusionstechnik GmbH has admitted to using a PFAS polymer, PVDF-HFP in the manufacturing of their synthetic turf.

On Monday, December 6th, a memo from the City of Portsmouth, NH staff stated that, “The manufacturer in Germany has produced Material Safety Data Sheets and the 3M additives used in their processes. Those MSDS sheets are attached. PVDF-HFP is a component of the additive.”

The City of Portsmouth was promised a “PFAS free” field prior to installation. It is becoming clear that they did not get what they paid for.

The City Council voted unanimously on December 6th to do further PFAS testing of the new field installed by Community Campus. It will be up to the new Council to decide what to do based on the data we get back.

City staff have repeated the opinions of the industry funded consultants that PVDF-HFP is “biocompatible, inert and insoluble” and that “this field is safe from our point of view, there’s no toxicological study that suggests that the additive that the manufacturer has used presents any risk.”

In contrast, Non Toxic Portsmouth have shared information with the Council about the leachability of PFAS polymers when exposed to UV light, and some preliminary evidence of the toxicity of PVDF while awaiting data from the City’s commissioned test results. 

Are Fluoropolymers Really of Low Concern for Human and Environmental Health and Separate from Other PFAS?

PFAS Polymers Pose Serious Health and Environmental Threats 

On the Solubility and Stability of Polyvinylidene Fluoride

Polyvinylidene Fluoride Alters Inflammatory Responses by Activation-induced Cell Death in Macrophages

When thinking about polymers, there is a need to consider the full life cycle, including manufacture, processing, and break-down during use and end of life. Polymers can break down into other PFAS over the course of product use and disposal. There is strong scientific support for regulating PFAS as a class rather than chemical by chemical.

We hope the new Council will and seek input and advice from independent public health scientists as they decide on how to proceed.

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Tests Detect Dangerous PFAS Chemicals in Portsmouth’s New Synthetic Turf Field

Independent testing of new artificial field confirm PFAS chemicals present in products

Independent testing of the new artificial turf field installed by the Community Campus shows that toxics known as PFAS contaminate the turf, shock pad, and backing of the plastic field. PFAS have been linked to numerous health problems from immune suppression to cancer. Here on the Seacoast, in the middle of a pediatric cancer cluster, we have become acutely aware of the danger of these “forever chemicals.”

The field testing was commissioned by the local citizen’s group Non Toxic Portsmouth. Last summer, the group, alongside Dr. Graham Peaslee, a physicist at the University of Notre Dame and one of the world’s top experts in detecting PFAS, personally urged the Portsmouth City Council to conduct independent testing of the synthetic turf product before installation. This warning was after lab tests had already found PFAS in Portsmouth High School’s ten-year-old Tom Daubney Field. In the letter to the Portsmouth City Council, disclosing the finding of PFAS at the high school field, Jeff Gearhart, MS, Research Director for the nonprofit Ecology Center advised, “A company claiming PFAS-free turf fiber should…be able to produce testing results showing less than 1 part per million of total organic fluorine or total fluorine.”

A motion to commission independent total fluorine testing was denied after the City Council had already approved the purchase of the new plastic field on a 5-4 vote. However, the City Council did stipulate that the new field must be “PFAS free”.  The City’s Request for Proposals did require that the new field be PFAS free, but despite the science and the experts’ recommendations, the city did not require independent testing. In the end the contractor tested for only 30 types of the thousands of PFAS chemicals and provided a letter from the manufacturer FieldTurf stating that it’s product is PFAS free and contains no fluorine.  In spite of no proof of being PFAS free the city spent $1.6 million and put the field in anyway. 

Non Toxic Portsmouth was able to obtain virgin samples of all of the new field’s components and had them independently tested under the guidance of the Ecology Center. The test results clearly indicate the presence of PFAS and directly contradict a statement by the manufacturer FieldTurf, that their “supplier has confirmed that their products are free of…fluorine.” Yet our independent testing showed a range of 119 ppm to 16 ppm of fluorine.

When presented with the results of this recent testing Dr. Peaslee said, “These total fluorine measurements are typical for plastics that have been manufactured with PFAS-based polymer processing aids – which will leave residues of these PFAS at the part-per-million level on the artificial grass. 3M sells these PFAS-based products and their sales brochure lists artificial grass as one of their applications, so they are definitely used within the artificial turf industry.” Dr. Peaslee directs a research program in applied nuclear science to screen for chemicals of concern in our built environment and to measure how these chemicals are dispersed in the natural environment. 

The night that the Portsmouth City Council gave final approval to new synthetic turf fields, some residents spoke in favor of them based on the promise that the new fields would be a PFAS free product. 

“Despite the assurances from city consultants and management, our kids will again be playing on a field containing PFAS,” observed Ted Jankowski of Non Toxic Portsmouth. “We have just installed this new multi-million dollar field that we were promised would be PFAS free, but our test results reveal it’s clearly not. The City Council too should demand financial accountability. We could have put in four state of the art natural turf fields for the cost of this one 100 ton plastic field.”

PFAS are not the only toxic chemicals found in synthetic turf. Plastics have been found to contain thousands of harmful compounds. Runoff from this new field runs directly into the newly constructed regional stormwater system and then into Sagamore Creek. Some of these chemicals can accumulate in humans and animals, like PFAS, and hundreds of them can be harmful even in small doses. We wonder – are these chemicals now leaching into Sagamore Creek?  

Diana Carpinone of Non Toxic Dover believes that, “These new test results support the position of our resident advocacy groups that organic natural grass fields are the safest choice for our Seacoast communities.”

View the 3M guide to fluoropolymer-based polymer processing aids – page 11 lists one application for these PFAS additives as artificial grass.

Read about the testing method used – GLI Method Summary

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Turf Services 2021 – Best Management Practices Not Being Followed!

Despite a switch to a fully organic program in 2020, our athletic fields and turf areas are not where they need to be due to a lack of proper cultural practices by mowing and irrigation vendors and city staff.

This is a frustrating turn of events, due to the fact that this puts the organic program at risk of failing because of the actions of the other professionals responsible for managing our public areas, including athletic fields.

The latest site report from the turf services vendor points out five main areas of concern. Mowing, weed whacking, baseball and softball fields (lack of regular maintenance of base paths), lack of athletic field safety, and irrigation.

Some of this is merely cosmetic concerns, but the unsafe conditions our playing fields are in is absolutely unacceptable! The city must commit to fixing this right away!

Make no mistake, this result is not not due to the organic program, or organic vendors who are contracted to provide soil fertility services for the turfgrass areas – this is due to a number of vendors and even our own staff sadly, who are not following basic, industry standard best management practices for turfgrass that apply whether or not a program is conventional or organic. No doubt there will be those who try to blame the organic program, but they would be wrong.

The good news is that all of this is fixable! And we have been improving the soil health and biology over the past two seasons, despite the lack of ideal weather conditions. This challenge can be overcome! But it is up to our staff and mowing and irrigation vendors if that happens or not.

The current vendor, PJC Organic, states in their report that they are willing to do an Organic 101 training session with maintenance staff, and make other suggestions on how the city can be successful, like the example of Byfield, MA, another town they also work with.

There is no reason Dover’s fields should be any less safe or beautiful – the lack of results we are seeing here are due to things that are all well within the control of city staff and vendors.

Please reach out to the City Council, City Manager and Community Services Director and Facilities and Grounds and ask them to attend to this matter immediately, and create a plan to get our athletic fields safe to play on, and make our turf services program a successful one.

CityCouncil-All@dover.nh.gov

m.joyal@dover.nh.gov

j.storer@dover.nh.gov

s.sirois@dover.nh.gov

UPDATE 9/9/21

During the last City Council meeting Councilor Shanahan and City Manager Joyal addressed the mowing and other maintenance issues for our public turf grass areas. (See discussion in video at 12:28) It looks like some of these things are beginning to be improved and will hopefully get on track before next spring. We are lucky to have a vendor for turf services that puts together detailed reports of their site visits so that we can make sure maintenance is being kept up with. A successful program hinges on the cooperation of everyone involved. Thank you to the Council and City staff for handling this matter. We will continue to keep an eye on things as they progress.

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2021 Curbside Weed Control – Still Organic!

Always happy to have good news to report, and this year’s turf services and curbside weed control are no exception. Earlier in the year the City continued their contract with PJC Organic for turf services, and at Wednesday’s City Council meeting they are set to approve a program for weed control on City curb lines, sidewalks and other hardscapes along 33 miles of Dover’s roads.

From the resolution background materials included in the June 9th agenda:

“Municipal Pest Management Services, Inc. provided a scope of services that proposes a SWEEP (Sustainable Weed Control on Pavements) Program for the 2021 season. The SWEEP program consists of crack filling, sediment removal and hand pulling.

Also included in the proposal is the use of an organic herbicide, Finalsan Herbicide, as well as the testing of several new organic herbicides for potential, all of which will be vetted by the Community Services Department.”

View the details of the SWEEP Program here:

This is the third year our curbside weed control program will be fully organic, and the second year for turf services. We are grateful to the City Council and Community Services staff who have made our streets, parks, and athletic fields a safer place to live and play!

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Dover School Board Fails Again in Their Responsibility to Our Community

Over the years, a pattern has emerged with the Dover School Board that cannot be ignored. After years of attempts by Non Toxic Dover members to work together with the board, the last regular meeting culminated with a display of their disregard for legitimate concerns brought forward about student safety and harm to wildlife as they discussed and voted on the draft policy written and submitted by our group.

Click Buildings & Grounds Management to watch their discussion.

After contacting the board about the fact that their Buildings and Grounds Management/Integrated Pest Management Program policy is being violated by subcontractors (and has been for years), the ward 4 school board member suggested that we draft a policy.

My suggestion is that you take the current policy and use your knowledge to write a policy to meet your standards and specifications. (Ward 3 school board member) and I are not experts in this field and even with talking with experts, we have a lot to still learn.

So your mission, should you choose to accept, is to lobby us with your written policy. Instead of giving us money, prove to us that your written policy is better than ours and make it impossible for us to not agree to back it at the school board.

We accepted this mission, assuming it was intended as a constructive way to resolve the issue for good. Unfortunately, repeated requests for a dialog were met with no response. We offered to discuss the formation of a committee and all other details of the policy. The last response received about two weeks before the final reading of the draft policy was to a follow up email we sent about the draft policy, from the ward 3 school board member. Here it is in its entirety: “It’s possible that no one has any questions for you.”

If you watched the discussion in the video linked above, CLEARLY there were questions and concerns! Unfortunately no school board members reached out to us to discuss them. Not one.

We are not at all unsympathetic to the fact that people are busy and the special circumstances we all find ourselves in at present time, however this is not an excuse to put ongoing issues that directly effect the health and safety of students and our ecosystem on the back burner.

It is the job of the school board to enforce their own policy and they have a longstanding history of not doing that. This is all a matter of record, and the actions of the board show that they are more interested in paying lip service to the policy, while in reality protecting the status quo. It’s their watch allowing subcontractors to lead staff around by the nose, while taxpayers foot the bill for toxic practices that violate district policy.

This has got to stop!

All the progress made to date has been as a direct result of action taken by our advocacy group members. It was a resident who brought in an expert to consult with them on the athletic fields, and a resident who took a course in school integrated pest management and gave them suggestions to use for rodent control. It was residents who have written in, asking them to do something about this situation, again and again over the years, some of whom have reported they received rude and dismissive responses.

That aforementioned expert, Mr. Osborne, was brought in because of the athletic fields subcontractor using blanket applications of a synthetic grub control, and because they planned to spray 2,4-D, dicamba and MCPP for weeds. He has never stated that the program was fine as is, the entire purpose of his visits were because things were not fine. If it were not for residents doing the job of the board, we’d still be violating the policy in regards to the athletic fields.

As far as the integrated pest management (IPM) program for the buildings go, it is laughable. Using rodenticides as a “prevention” and spraying synthetic pyrethroids for a nuisance pest like ants, is not IPM, and will never be. We have shared resources with the Superintendent.

He stated in a letter dated February 23, 2021, “Thank you for reminding us of the need to implement this new policy and the important issues that underlie it,” and “...the district needs to identify if and to what extent its current system should be amended in light of the new policy.”

A response was sent by email the same day.

The resources shared regarding safer rodent control can be found below.

The joke made during the meeting about the “hawks not doing their job” was especially insensitive given that this information had already been shared with them, and the school board was defending the subcontractor’s practice of setting out poison baits which perpetually poison the raptors food supply. We have already shared examples of baby owls poisoned by rodenticide locally as well. This is not a good look for the board.

Plenty of other municipalities and school districts manage their properties without the use of toxic rodenticides, most recently the city of Malibu, California had a full ban approved after extensive coordination between multiple state, county and municipal agencies alongside a local advocacy group. That level of effort illustrates just how important this issue is. And yet, our school board who state that they “are the oversight” are willfully failing to collaborate with residents like myself, and other members of our group to resolve pest issues without resorting to the use of toxic compounds that put students and wildlife in harm’s way. It’s extremely disheartening.

The members of Non Toxic Dover are always willing to work together with school board members who want to engage us in good faith.

So far, our experience with our representatives has been that they are preoccupied with other matters and do not think that protecting students from toxic chemical exposures, or protecting the natural resources of the land we live on is something that they need to prioritize. But the mess we find ourselves in today with the pandemic, climate and biodiversity crisis, is precisely the result of this sort of attitude.

For years there has been a systemic failure of the district to make sure we conduct our buildings and grounds management in a responsible way. Both the board and the staff have taken the easy way out by relying on third-party subcontractors to dictate our practices. Residents who have tried to step up and change things are met with resistance at every turn, and even unprofessional rudeness and mocking at times from people who are supposed to represent them. All of this is absolutely inexcusable. It is not the job of parents, residents, or Non Toxic Dover to oversee that policy is being followed. This is the job of the board and any failure on their part is due to pure willful negligence at this point.

The only thing standing in the way of what could be a pleasant collaborative exchange of ideas and a learning experience that improves safety for students and the environment is the school board’s lousy attitude.

It is our hope that the school board will stop making poor excuses as to why they can’t practice IPM or organic land care that so many other school districts, universities and municipalities are embracing, and do the job that is expected of them. We will be here waiting, and watching.

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