Synthetic Turf

Cc: Ms Tracy Mackey

CEO NSW Environment Protection Authority

Dear Minister Kean,

We are writing to you regarding our ongoing concerns about the continued use and apparent expansion of the use of synthetic turf on NSW playing fields.

We first raised our concerns with our local government authority, The Hills Shire Council, in March 2019 in relation to a synthetic turf playing field proposed for the West Pennant Hills Valley. We believe that like many NSW councils, the Hills Shire Council continues to see a benefit in using synthetic turf and that we are likely to see more plastic playing fields in our local area.

Much is made of the inability of natural turf to cope with the pressure of the increasing demand for the use of playing fields. It is also suggested that there is a cost benefit in changing to plastic. We are aware of studies and comments by experts in this area that if designed and maintained properly, fields with natural turf can generally support significantly higher usage than the proponents of synthetic turf fields would have us believe and that the real cost benefit is to be found in keeping natural turf.

We agree that prioritising participation in active and passive recreation has enormous benefits for us all and understand that there is an increasing demand for recreational spaces placing pressure on our existing natural grass fields.

However, we have serious environmental and public health concerns about achieving this goal through replacing natural grass with plastic grass. Given the real possibility of negative outcomes arising from the use of synthetic turf and the lack of scientific data about its long-term effects, we believe that we should embrace the precautionary principle and stop its use in NSW.

We recently made an on-line submission to The Department of Planning, Industry and Environment’s Synthetic Turf Study. Whilst we commend Minister Stokes for his actions in initiating this study, we believe that this discussion needs to include both your office and the NSW EPA as the state’s primary environmental regulator.

The recent release of the NSW Waste and Sustainable Materials Strategy 2041 and its associated NSW Plastics Plan clearly support the need to use less plastic and improve the way we manage plastic waste and pollution. They suggest that we do understand the inappropriateness of the continued use of plastic grass.

We have calculated, using data from a study by the Federation Internationale de Football (FIFA), that, on average, a single synthetic playing field will lose the equivalent of half a million single-use plastic bags into the environment every year. In addition, at the end of its life we will need to dispose of the equivalent of an average 30 million single-use plastic bags.  The end-of-life figure is based on disposal of the blades, backing and infill and does not include an allowance for any plastic in the shockpad and underlay which may also require disposal.

Plastic playing fields are often located in positions where there is significant run-off into our waterways. We question how the use of synthetic turf and especially synthetic turf using plastic or recycled rubber infill, could possibly comply with the NSW Protection of the Environment Operations (POEO) Act 1997 in terms of materials being washed off-site, and especially the Protection of the Environment (Waste) Regulation 2014 in the case of fields using re-cycled tyre waste as infill?

Some of the significant problems that cause us to object to the use of synthetic turf are summarised below.

TEMPERATURE - we have measured local synthetic turf playing fields at temperatures exceeding 80 degrees C, and 20 to 50 degrees C above adjacent natural grass in hot weather. Users, particularly children, can suffer from heat stress and injury.

Water can be used to cool the field but it will reheat quickly as it lacks the cooling transpiration of natural grass.

MICROPLASTIC POLLUTION - Plastic particles from 5mm down to microscopic levels are seen as one of the greatest environmental burdens and threats today. These particles, found throughout our environment, especially oceans, are now in our food chain and have been reported in human stool samples.

Globally governments and industry are working to dramatically remove plastic from the environment. Plastic playing fields shed microplastics into the environment from both the plastic turf fibres and its infill, usually artificial rubber or plastic. These microplastics pollute water catchments and the ocean.

Pollutants in the marine environment will adhere to microplastic particles increasing the potential for damage to the environment and the planet’s food chains.

Some studies have shown that microscopic particles generated from plastic playing fields can form a respirable dust ready to be inhaled by children using the field.

CHEMICAL POLLUTION - The plastics used in the fibres and the usually synthetic in-fills are created from petrochemicals and contain many toxic chemicals including known carcinogens which will be leached, outgassed and physically broken off and swept into the environment.

The plastics used in playing fields have been shown at times to contain PFAS and lead. Given our global concerns about the environmental and health effects of these contaminants we need to understand how plastic fields may or may not contribute to this environmental burden.

END OF LIFE DISPOSAL - Depending on the level of usage and maintenance, synthetic turf will need replacing after 8 to 15 years. There is no infrastructure in place to recycle the plastic.

The plastic will be too dirty to recycle without some significant cleaning. Any cleaning solutions used are likely to become heavily contaminated with microplastics and will become a significant environmental issue in themselves. Landfill is still looking as the most likely end for a plastic field where it will continue to shed microplastics and chemicals into the environment.

It has been suggested that the disposal problem may be managed by burning the waste for energy which may not be approved and also raises additional environmental concerns.

INJURIES - Synthetic turf can be a harder and more abrasive surface than natural grass and many sports health professionals and players believe that it contributes to greater sports injuries.

We believe that there is a real opportunity for NSW to become a national and international leader by embracing the creation of well-designed and maintained, sustainable playing fields using natural grass.

We would welcome your comments and the opportunity to discuss our concerns with you in greater detail.

Peter Ernst, President & Joan Rowley, Vice President

on behalf of

The Committee, West Pennant Hills Valley Progress Association

Email: wphvpa@gmail.com

Website: wphvpa.org

2021-06-04 WPHVPA Submission to the DPIE Synthetic Turf Study

(limited to a maximum of 500 words)

We agree that prioritising participation in active and passive recreation has enormous benefits for us all and understand that there is an increasing demand for recreational spaces placing pressure on our existing natural fields.

However, we have serious environmental and public health concerns about achieving this goal through replacing natural grass with synthetic turf. Given the real possibility of negative outcomes arising from the use of synthetic turf and the lack of facts about its long-term effects, we believe that we should embrace the precautionary principle and stop its use in NSW.

Some of the significant problems that cause us to object to the use of synthetic turf are summarised below.

TEMPERATURE– we have measured local synthetic turf playing fields exceeding 80 degrees C, and 20 to 50 degrees C above natural grass in hot weather. Users, particularly children, can suffer from heat stress.

MICROPLASTIC POLLUTION - Plastic particles from 5mm down to microscopic levels are seen as one of the greatest environmental burdens and threats today. These particles, found throughout our environment, especially oceans, are now in our food chain and have been reported in human stool samples.

Globally governments and industry are working to dramatically remove plastic from the environment. Plastic playing fields shed microplastics into the environment from both the plastic turf fibres and its infill, usually artificial rubber or plastic. These microplastics pollute water catchments and the ocean.

Pollutants in the marine environment will adhere to microplastic particles increasing the potential for damage to the environment and the planet’s food chains.

Some studies have shown that microscopic particles generated from plastic playing fields can form a respirable dust ready to be inhaled by children using the field.

CHEMICAL POLLUTION – The plastics used in the fibres and the usually synthetic in-fills are created from petrochemicals and contain many toxic chemicals including known carcinogens which will be leached, outgassed and physically broken off and swept into the environment.

The plastics used in playing fields have been shown at times to contain PFAS and lead. Given our global concerns about the environmental and health effects of these contaminants we need to understand how plastic fields may or may not contribute to this environmental burden.

END OF LIFE DISPOSAL – Depending on the level of usage and maintenance, synthetic turf will need replacing after 8 to 15 years. There is no infrastructure in place to recycle the plastic. The plastic will be too dirty to recycle without some significant cleaning. Any cleaning solutions used are likely to become heavily contaminated with microplastics and will become a significant environmental issue in themselves. Landfill is still looking as the most likely end for a plastic field where it will continue to shed microplastics and chemicals into the environment.

INJURIES – Synthetic turf can be a harder and more abrasive surface than natural grass and many sports health professionals and players believe that it contributes to greater sports injuries.

We need to look at how more sustainable playing fields can be created using natural grass.  

-------------------------------------------

2021-06-04 Submission to the DPIE Synthetic Turf Study

This is a personal submission from the Vice-President of West Pennant Hills Valley Progress Association.

I object to the use of artificial turf on environmental grounds.  Plastic playing fields are yet another example of how technological solutions can appear to succeed, but only at the cost of seriously polluting our environment.

Depending on usage and maintenance, most synthetic surfaces need replacing every 8-15 years, and currently there are no recycling facilities in NSW.

For every synthetic sportsfield, there are the equivalent of 30 million single-use plastic bags going to landfill every 8-15 years, plus the equivalent of another half million bags leeching into the environment every year.

In 2019, The Hills Shire Council (THSC) proposed using artificial turf for a site in my suburb.   Also in 2019, there was much discussion about banning the use of single-use plastic bags.  That prompted me to investigate the plastic bag equivalent of a synthetic playing field.

A useful resource for the calculation was a report on the FIFA website ‘ENVIRONMENTAL IMPACT STUDY ON ARTIFICIAL FOOTBALL TURF’.   See FIFA EIS on Artificial Turf 

The results of my investigations were as follows:

·        The blades, backing and infill of a new synthetic pitch are equivalent to nearly 30 million single-use plastic bags (this excludes any plastic used in shockpad or underlay);

·        The average amount of infill escaping each year from one synthetic pitch is equivalent to around half a million single-use plastic bags.  This infill pollutes the soil and our waterways, and enters the food chain.

These calculations are based on the following assumptions:

·        Pitch size of 72m x 106m (as proposed by THSC)

·        Average weight of a single-use plastic bag is 5g

·        Average amount of infill lost and replaced each year is 2.5% of total (derived from FIFA report)

·        Average combined weight of blades, backing and infill is 18.6kg/sqm (derived from FIFA report)

We don’t need more landfill and more pollution.  A natural turf playing field constructed with good drainage is the obvious choice for our sporting venues. 

FIFA EIS on Artificial Turf A report commissioned by FIFA that studies the environmental impact of synthetic turf.
https://www.safehealthyplayingfields.org/  A very complete web page from an American group that discusses all aspects of comparing grass and plastic fields including costs, maintenance, environmental and health issues as well as current law suits etc.
http://www.kimointernational.org/feature/microplastic-pollution-from-artificial-grass-a-field-guide  A very good summary of microplastic pollution from playing fields produced by KIMO a Scandinavian association for sustainable seas
https://www.illawarramercury.com.au/story/5422307/fears-uows-synthetic-football-pitch-will-be-an-environmental-disaster/  An Australian perspective regarding plans to use synthetic playing fields by the Uni of Wollongong and Wollongong council.
http://theconversation.com/why-artificial-turf-may-truly-be-bad-for-kids-72044  A short summary by an environmental scientist covering many of the concerns.