GREENS NSW SUBMISSION TO THE SYNTHETIC TURF IN PUBLIC OPEN SPACE GUIDELINES
Submission prepared by Dr Amanda Cohn MLC, Greens Spokesperson for Sport and Recreation
1. Introduction
The Greens are committed to fostering inclusive and accessible community sports and recreation for all. This, along with the increasing demand for green space in our communities will only become more of a challenge as our population grows.
Safe and sustainable infrastructure in our communities ensures that everyone has access to quality recreational environments.
The Greens welcome the NSW Government’s drafting of the Synthetic Turf in Public Open Space: Guidelines for Decision-Makers (“the Guidelines”). They mark a starting point on the journey to ensuring that turf in public spaces in NSW is well planned and maintained and meets high environmental and health standards. However, the Guidelines as drafted do not provide clear assertive direction for decision-makers to take a structured approach to considering and managing synthetic turf.
It is of concern that the Guidelines have been drafted before the NSW Government has formally responded to the Chief Scientist & Engineer’s Independent review into the design, use and impacts of synthetic turf in public open spaces Final Report (the “CSE report”).
There has been a six-fold increase in synthetic turf replacing natural turf sports fields in the past five years in NSW, and the rate of installation is increasing. This increase is extremely concerning in the context of the CSE report and draft Guidelines both acknowledging knowledge gaps regarding impacts on human and environmental health. While further research is needed and welcome, the Greens believe that there should be a moratorium on approvals and funding for synthetic turf installation in public open spaces while this research is undertaken.
However, the Greens appreciate the opportunity to contribute to this consultation and hope the process will refine and strengthen the Guidelines.
We would welcome the opportunity to discuss any part of this submission and can be contacted via the office of Dr Amanda Cohn MLC at [email protected].
2. Heat impacts on human health
The CSE report identified that the heat retaining property of synthetic turf can cause heat stress and heat-related illness, and is potentially hazardous for children, especially when unshaded, as its surface can be up to 38 degrees hotter than that of natural turf. Other sources report that the surface of direct sun on rubberised soft fall can be 50 degrees celsius hotter than the ambient temperature.
Further, the cumulative depletion of grass surfaces over time may exacerbate urban heat island effects and increase heat exposure risk in the population, while natural turf maintains low surface temperatures even on hot days due to cooling by evapotranspiration and low thermal mass. Synthetic turf can generate greater stress on players’ feet and may have the effect of increasing heat strain due to the exposure of individuals to higher loads of directly reflected solar radiation.
Video recordings made by nearby residents in December 2023 demonstrate synthetic turf fields in Sydney with surface temperatures approximately 30 degrees higher than adjacent concrete pavement. These videos can be made available upon request.
The draft Guidelines fail to provide specific guidance relating to children using synthetic turf surfaces for sport and recreation. This should be included given that children face an increased risk of heat-related illness or injury, and are susceptible to quickly becoming dehydrated and unwell. A shoeless toddler can suffer 3rd degree burns on a 50 degree celsius surface.
The draft Guidelines highlight the higher surface temperatures of synthetic turf and the potential impacts on player and user comfort, particularly noting that in very hot weather, play can be cancelled due to heat stress. However, they do not contain guidelines or advice for non-sporting recreational activities for managing heat exposure or safety on hot synthetic surfaces.
This omission is significant because it reflects a gap in considering the full range of uses and users of public open spaces, particularly when natural turf facilities are being replaced with synthetic turf. Dangerously hot surfaces may prevent people from undertaking both organised and passive recreational activities.
The draft Guidelines note the need to analyse the impact of heat on larger fields and the potential for higher UV reflectivity of synthetic turf. This analysis should be prioritised by the NSW Government before continuing with the installation of synthetic turf fields, particularly given the predicted increased number of very hot days each summer due to climate change, and that heatwaves kill more Australians every year than any other natural hazard.
3. Environmental concerns
The CSE report includes concerns about the impact of synthetic turf on the surrounding environment, including:
- potential for increased water runoff due to the non-absorbent nature of synthetic turf, which can lead to greater pollution in water systems;
- degradation of synthetic materials can lead to leaching of chemicals into the environment, which poses risks to soil and water quality;
- replacing natural grass with synthetic turf can lead to habitat loss and disrupt ecological functions;
- rubber infill and turf fibre blades from synthetic turf fields being found in waterways in NSW.
The NSW EPA have echoed concerns around the lack of understanding about the potential impact of microplastics and chemicals in synthetic turf on waterways and soils. It has stated that work is needed to be done to identify mitigation measures and guidance for stakeholders. Filling this knowledge gap should be prioritised by the NSW Government before continuing with the installation of further synthetic turf.
The Guidelines should align with the recommendations of CSE report by setting comprehensive and strict criteria for all materials used in the construction of synthetic turf, including the availability of Material Safety Data Sheets for each material providing details on the materials’ recyclability and their environmental and health impacts.
The CSE report identified several gaps and important environmental considerations missing in the Review of Environmental Factors (REF) process. This process must be reviewed by the NSW Government to ensure all environmental impacts are considered at potential synthetic turf sites, with priority to the gaps identified in the CSE report. In addition, REFs should address end-of-life plans for synthetic turf.
4. Planning, installation, and maintenance
Natural turf condition and perceived carrying capacity are commonly cited reasons for synthetic turf installations. The performance of sporting fields is strongly influenced by soils, drainage, turf variety, irrigation systems and climate conditions. As the Guidelines themselves note, the upper limit capacity of a well-engineered and well-maintaned natural turf field is on par with synthetic turf at approximately 60 hours per week. It is of serious concern that athletes and communities are being exposed to both the known and unknown risks of synthetic turf because local government and sporting clubs are not adequately resourced to maintain natural turf to its full capacity.
State (and federal) governments frequently fund capital works for sport and recreation facilities including turf fields, leaving local government or sporting clubs to pay for the ongoing maintenance. In the context of significant issues of financial sustainability impacting the local government sector, the NSW government should consider opportunities to support local government to maintain natural turf in public open spaces.
The NSW government has indicated that it is developing in parallel a best practice irrigation guideline for natural turf. The Greens believe that best practice planning, design, installation and maintenance guidelines for natural turf (not limited to irrigation) are required urgently and should be included with these Guidelines.
Consultation and transparent communication with the community and all stakeholders should play a key role throughout the process, and occur at all stages of planning, funding and development - not only once a Development Application is under consideration. Community and advocacy groups have raised concerns that planning for synthetic turf fields in some cases has been undertaken by local government without early community consultation, and without sharing information regarding analyses undertaken by the council.
The CSE report recommends adopting minimum open data standards and encourages engaging with the synthetic turf industry towards sustainable practices. The draft Guidelines touch upon sustainability and the need for best practice guidelines but do not explicitly lay out guidance for data standardisation or specific sustainable practices in synthetic turf installation and maintenance.
5. Increased bushfire risk and exacerbation of flood impacts
Synthetic turf fields, due to their largely impervious nature, can contribute to water runoff during rainfall. Studies have indicated that compared to natural turf, synthetic fields can reduce soil infiltration rates and increase runoff, leading to potential water management challenges, especially during heavy rainfall events.
The CSE report highlights the unsuitability of synthetic turf for regions prone to bushfires: the material composition and heat absorption properties of synthetic turf can exacerbate bushfires, with a recognised risk of synthetic turf contributing to the ignition of nearby structures during bushfires.
As climate change progresses, increased temperatures and more frequent extreme weather events could intensify these risks and this must be seriously considered in planning processes.
The CSE report recommends that assessment and testing of synthetic turf in bushfire and flood-prone areas be conducted in collaboration with relevant NSW Government emergency service agencies and supplemented by independent expert advice. This is to ensure that all potential risks are comprehensively evaluated and managed.
Given these risks, the Guidelines should set specific prohibitions or, at a minimum, strong cautionary advice against installation in areas at risk of bushfires or flooding. Additionally, councils and emergency services in these regions should be equipped with specific guidance on how to effectively communicate and manage risks associated with existing synthetic turf in the face of extreme weather conditions to mitigate potential damages and enhance community safety and preparedness.
6. School settings
The Guidelines as drafted do not apply to private or government owned property, such as schools, but they could and should also be applied to the many synthetic turf installations on these premises. We acknowledge the Guidelines were drafted by the NSW Department of Planning, Housing and Infrastructure, but an inter-agency approach should be taken to broadening their scope to include guidance for synthetic turf in school settings.
There is a knowledge gap and lack of regulatory framework concerning the use of synthetic turf in school settings. This is despite children being at greater risk of heat-related illnesses and injuries (as mentioned in earlier sections). The only guideline for schools using synthetic play equipment (not defined as synthetic turf) in the Education Facilities Standards and Guidelines is: “Shade is required for synthetic play equipment and surfacing to reduce the risk of contact burns from direct sunlight.“ The Guidelines as drafted are a missed opportunity to address this.
The knowledge gap and lack of regulatory framework persists despite the fact that there are synthetic turf surfaces in Category 1 bushfire risk schools. Given the exacerbated bushfire threat synthetic turf creates, school infrastructure and students, staff and visitors may be being placed at unnecessary risk.
The scope of the Guidelines should be broadened to include safety information for decision-makers at schools and the NSW Department of Education when considering the installation of different kinds of turf. Part of this work should be mapping the schools in high bushfire risk areas with synthetic turf surfaces that need tailored safety information.
7. Conclusion
The issues outlined in this submission - human health and environmental impacts, the exacerbation of bushfires and flooding, lack of best practice natural turf management in NSW, and risks to students and staff in schools - are substantial. The Greens reiterate that there should be a moratorium on approvals and funding for synthetic turf installation in public open spaces while further research is undertaken.
However, we hope the Guidelines can be strengthened and refined in response to the current consultation. The NSW Government must engage with community groups, health experts, environmental scientists, and other relevant stakeholders to understand their concerns related to synthetic turf.
We wish to acknowledge in particular the ongoing advocacy of voluntary community groups that are advocating for sporting and recreational facilities that are safe for our health - now and into the future.