An AFL Players' Association submission on the interchange system says that a proposed cap on rotations will have a negative impact on player welfare and safety and the spectacle of the game.
All players were emailed the submission on Friday afternoon, just days ahead of Monday's AFL Commission meeting when the question of whether or not to introduce a cap for next season will be considered.
While the AFLPA accepts the Commission has genuine concerns about high rotations leading to injury rates, it says there is insufficient evidence to support a link between the two.
Players say there is no doubt a cap will increase player fatigue and that injury rates may in fact increase, or at best remain stable instead of reducing, if it is introduced.
It also argues that the greater physical demands on players will mean more time is needed for recovery, which could have a negative impact on work/life balance.
The submission, which has been posted on the Players' Assocation website, presents evidence to support its claims and concluded with the following:
The need to cap interchanges is unproven and has the potential, indeed the probability, that it would place players at greater risk of injury through increased fatigue.
As we have previously submitted, there is not enough injury data, or developed analytics, to properly assess either the impact of reducing rotations, or the impact this may have if player fatigue levels are increased as a result of any such change.
Player speed has decreased significantly since the 3:1 rule was introduced. However, this has not had any substantive impact on reducing injury rates, which have remained fairly constant despite the drop in player speed. However, calves (fatigue related injury) have increased at alarming rates.
The AFL Commission accepted the need for a cap in principle in October 2012 but wanted to examine further evidence before it was introduced.
Most clubs and players were of the view that the deferment meant the cap's introduction would be up for debate.
However AFL CEO Andrew Demetriou quickly quashed discussion of the issue and surprised clubs when he said the only question remaining for debate was the figure at which the interchange would be capped.
However, interchange averages per team have stabilised at just above 130 since Demetriou's comments and the AFL has appointed new football operations boss Mark Evans, who was previously at Hawthorn.
At his press conference on Tuesday, Demetriou said the Commission would "consider an interchange cap, if any, for 2014."
The words 'if any' were not included in the official media statement.
Evans made a presentation at the most recent AFL Commission meeting and was asked to gather more information relating to the possible link between interchange rotations and injury rates.
The AFLPA says it has made the submission because of the Commission's request for more detail.
It also argues that a proposed cap will have an "adverse impact on the spectacle of the game" because it will lead to negative coaching tactics such as tempo football and reduce the ability of players to explode off the mark and escape stoppages, which will lead to even more congestion.
It is understood the Laws of the Game committee, which now has a coaches' representative in Rodney Eade, is now less certain about the need for a cap than it had been during 2012.
There are also concerns with how the cap would be administered in a practical sense on game day.
Meanwhile, clubs with young lists such as Greater Western Sydney and clubs entering the finals such as Fremantle, Hawthorn and Geelong have recorded high interchange rates in recent weeks.
Fremantle coach Ross Lyon indicated after his side's win over GWS that that high interchange rates were useful to freshen the team up for finals.
"We did higher than normal number of rotations today to try and share the running and load on some of the guys," Lyon said.