The Necessary Evil
Europe's "green" industry begs for an exemption from proposed "forever chemicals" ban after getting caught with its pants down.
Let's not have a double standard. One standard will do just fine. - George Carlin
Being an “environmentalist” in the twenty-first century developed world is hard work. You might be required to travel thousands of miles on a private jet to gather with 70,000 of the world’s most dedicated “leaders” at a conference to “solve” climate change. Or drive hundreds of miles to a climate protest in an internal combustion engine vehicle to glue yourself to the street with adhesives made from petrochemicals. Contributing to the problem in order to “fix” it is just an unfortunate consequence.
Things get even more complicated where the “alternative energy transition” intersects with environmentalism’s historic (and more useful and relevant) role: reducing risks to human health and the environment from chemical compounds.
Suppose for a moment that an advanced nation’s political leaders and environmental regulators proposed a ban of an allegedly dangerous class of chemicals. After doing so, they realize that particular group of compounds is important, possibly critical, to the very technologies on which their CO2 emissions-free future depends. If that compound were so dangerous to human health and the environment as to require an outright ban, surely “environmentalists” and their political “leaders” would never be so brash as to turn around and ask for exemptions just for “green energy”, would they?
This is not a rhetorical question. This exact scenario is currently playing out in the European Union (EU).
As we noted in Politics Fear and Science, per- and polyfluoroalkyl substances (PFAS), known to the public as “forever chemicals” are simultaneously on the verge of some of the strictest regulation of any compound in human history and are critical to a wide range of “clean” energy technologies. But in Europe, arguably the center of the advanced world’s most virulent environmental advocacy and broad (but waning) political appeal, some of the EU’s most notable “green” leaders who called for a ban on PFAS earlier this year are calling for exceptions for “alternative energy”.
In January 2023, five European countries - Germany, The Netherlands, Sweden, Denmark and (non-EU member) Norway - submitted a “restriction” proposal to the European Chemicals Agency (ECHA), to ban the production and most uses of PFAS under EU chemical regulations (known as REACH), with limited exceptions. Curious readers can find the slide deck European environmental officials presented at the media event introducing the proposal here, and the full proposal here.
The proposed ban is the culmination of several years’ scientific review and consultation on PFAS risk. Whatever restrictions or bans ultimately result from the proposal would likely come into effect in 2026 or 2027 after an eighteen month “transition period”.
PFAS compounds have become so ubiquitous across a wide variety of products that the proposal necessarily provides time-limited exemptions or “derogations” for certain industries and applications. These range from 5 - 12 years, including for “energy industrial applications”.
The proponents conducted several years of outreach across a variety of European industries. Under “Electronics, semiconductors and energy”, Annex G of the proposal notes (emphasis added):
For the electronics and semiconductor sector, around 30 stakeholders were contacted. A similar number of stakeholders related to the energy sector were contacted.
Annex G concludes with the statement (emphasis ours):
“the Dossier Submitters made considerable attempts to reach out to all relevant stakeholders regarding the use of PFASs and possible alternatives.”
ECHA’s comment period on the proposal ended September 25th. Their news release the next day noted 5,600 comments were received.
Germany, Europe’s (hemorrhaging) center of industrialization, is one of the five nations proposing the restriction. Ironically, German “alternative energy” manufacturers were either not considered “relevant stakeholders” or were too busy preparing requests for government bailouts and trying to survive to notice what was happening. Incredibly, it appears as if they failed to have a seat at the table during the consultation period, despite knowing that wind, solar, electric vehicles, battery storage and “green” hydrogen electrolyzers all depend to one extent or another on PFAS.
Germans, however, being the wise bunch on matters of energy, environment, and the economy, did not take long to realize the compounds they proposed to ban threatened to derail their production of the very technologies on which their “Energiewende” relies. By late spring, it was clear their own proposal was another threat to their suicidal energy strategy.
An August 4, 2023 Euractiv article quoted German (one-man wrecking ball and Green Party member) Federal Minister for Economic Affairs and Climate Action Robert Habeck, who (correctly) notes that PFAS play a key role in (emphasis added):
“technologies of the future,” such as semiconductors, electrolysers, and electric engines, many of which are key for the green and digital transitions. Here, PFAS cannot simply be replaced, and here we must not prevent the development of technologies by over-regulating them,” adding that a regulatory framework should be found which allows exemptions for “key technologies.”
Two weeks later, on August 17, 2023, ECHA logged comments and a request for an exemption from (German bailout recipient) Siemens Energy on the restriction proposal. Siemens Energy’s comment noted (emphasis ours):
“For a wide range of PFAS applications like cables, sensors, tubes, hoses, semiconductors, surface coating of equipment, sealings and many other applications, intentionally added PFAS (mostly Fluoropolymers) are used, ensuring an extreme durability and lifetime in some applications of 40 years or more.”
Commenting on the impact of the proposed restriction, Siemens Energy continued:
“The significant impact became obvious during our assessment of PFAS, not only on the business figures and employment but also on the development and market ramp-up for new (‘green’) technologies closely linked to projects focusing on renewables, green hydrogen, net zero technologies and a sustainable society.”
“...where a replacement is possible, the complex way of identification, finding a replacement, implementing them in products and finally repeating type testing of related products will also exceed the given transition time of 18 months by far.
In America, the evolving approach to PFAS risk is a combination of regulation (without banning) and manufacturers’ voluntary withdrawal of certain PFAS compounds for fear of tort liability and the plaintiff’s bar. EPA will use its authorities under the Safe Drinking Water Act, Superfund (The Comprehensive Environmental Response, Compensation and Liability Act), the Clean Air Act and similar laws to regulate PFAS, and ten U.S. States already have their own enforceable drinking water standards. The U.S. Food and Drug Administration already regulates PFAS in food packaging.
In Politics Fear and Science, we noted EPA’s proposed thresholds in parts per trillion are among the lowest of any chemical compound in history. Remediating PFAS in groundwater to those standards will be enormously costly. Taxpayers will foot much of the bill, whether from Department of Defense airport facilities or by inheriting the cost of bankrupt responsible parties under Superfund.
As we also noted in that post - linking to this Chemours Fluoropolymers “Renewable Energy Fact Sheet” -PFAS are widely used in a variety of “alternative energy” applications. Major PFAS producer Chemours has several website pages noting the importance of PFAS to “renewable” energy which provide a brief primer on critical applications in wind, solar and battery storage as well as EVs, heat pumps, and hydrogen production.
Despite the fact that information about the use of PFAS in alternative energy technology is widely known and in the public domain, German leadership either ignored or got caught flat footed about the importance of PFAS to its “Energiewende”. This is another example of government Charlaticians™ failing to understand how the world they are attempting to control actually works. As an October article in Cipher noted (emphasis added):
The cleantech sector was not included in the exemptions for a mix of reasons, according to several industry officials Cipher spoke to on the condition of anonymity to speak candidly.
They said cleantech companies didn’t lobby proactively enough for an exemption at earlier stages of the proposal deliberations, the environment departments within the five countries crafting the proposal largely did not consult with their energy counterparts and cleantech developers are not always sure if their products contain PFAS and figuring out if they do takes time.
On one hand, to be fair to German officials now scrambling for an exemption from their own proposed ban, PFAS range from substitutable to critical for some wind, solar, battery storage, EV, and hydrogen applications. For some, no functional substitute presently exists, and due to the unique strength of the carbon – fluorine bond and the relevant properties it enables, it is possible none may be found. Also, to our knowledge no long-term leachability studies specific to solar panels, wind turbine blades and other “green” energy hardware have been conducted showing long-term leaching of PFAS from these materials into soil or groundwater when landfilled.
On the other hand, millions of tons of wind and solar waste are going to be piling up in landfills in advanced nations. And landfills which have yet to receive any waste from wind, solar or other “alternative energy” projects are where some of the highest concentrations of PFAS in groundwater have already been detected. For reference, the values in the image below from monitoring wells (MW) and surface water (SW) sampling points around this closed landfill in Hoosic River, NY would be well above the threshold requiring remediation of ~5 to 70 parts per trillion (ppt) we anticipate if EPA lists PFAS as hazardous substances under Superfund (currently pending).
Denmark joined Germany among the five nations proposing the EU PFAS restrictions, and we suspect Danish environmental officials also failed to understand how PFAS relates to the nation’s wind and other “green” industries. Denmark is home to Orsted and Vestas, two of Europe’s largest wind energy firms, both of whom have struggled in the 2023 storms facing the industry, especially offshore projects.
Helpfully, European chemical industry watchdog groups began producing “investigative reports” shortly after the proposed the PFAS ban. We give credit to Sweden-based ChemSec for one-upping the IMF’s absurd fall report suggesting hydrocarbon fuels receive $7 trillion in annual subsidies globally. In May, the Swedish environmental non-profit, which bills itself as the International Chemical Secretariat, issued a report finding that (emphasis added) “The global societal costs – remediation, health care etc. – of PFAS chemicals amount to €16 trillion per year.” Not to be outdone on the cost of environmental externalities, ChemSec concludes PFAS’ human health and groundwater remediation costs to be more than twice the IMF’s cost of all human heath, environmental and climate-related costs from all forms of hydrocarbons combined.
Panelists on a recent Euractiv web debate “PFAS and the Green Transition – How Can We Strike a Balance” framed the battle that will play out over the next two years in the EU’s REACH regulation process over the proposed PFAS ban.
Kestutis Kupsys, Vice President Lithuanian Consumer Alliance, stated “We should not use the green transition as an argument to use substances which will then cause us other huge damages in our health and environment”.
Dr. Florian Henkel, Lead Global External Affairs & Govt. Relations for Cellcentric (a Volvo/Daimler fuel cell joint venture) summarized the predicament for “green energy” manufacturers, noting (emphasis added): “The industry is in a dilemma, I can tell you here, and it’s very simple. For fuel cells, PFAS are the functional element of fuel cell itself. And if you take that out, the fuel cell can’t function anymore, and electrolyzers it’s the same thing. So basically, we ban these substances we will ban the entire industry of fuel cells and electrolyzers in Europe. In fuel cells and in electrolyzers, without PFAS you don’t make them.
We close by noting this is another example of the “ready, shoot, aim” level of critical thinking commonly on display in many aspects of the “alternative energy transition” and a consequence of “leaders” failing to comprehend the most basic aspects of the world around them. Few of the EU PFAS ban’s loudest and most influential supporters - including Charlaticians™ and environmental groups – understood how widespread and important PFAS are to the very technologies on which they are relying. German leaders like Robert Habeck now attempting to secure exemptions for “alternative energy” from a ban of something so allegedly dangerous they introduced it themselves makes the perfect 2023 complement to Germans burning more lignite coal since Putin’s 2022 invasion of Ukraine.
There is another inescapable paradox in this episode. It brings into stark relief the ignorance and futility of monolithically viewing “carbon,” oil, natural gas, and coal solely through the lens of “climate change”. If, as Dr. Henkel noted, PFAS are critical to alternative energy systems, then since oil and natural gas are feedstocks for PFAS, they are a necessary evil if wind, solar, battery storage, EVs and hydrogen from electrolysis are to be our future.
Being an “environmentalist” in the twenty-first century developed world is getting more complicated by the day. Most of that complication is of your own making.
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If the environmental left ever came up with two consistent logical thoughts in a row its likely they would die from the effort.
Here in Canada the federal government of radical extreme environmental left just got slapped down by the courts for trying to over reach and ban plastics as "toxic".
This is the same federal govt that just threw $400million into the pot to help the DOW net zero project in Ft Sask, AB to proceed, a project that will produce plastic.
As always, i wish i could make this up or say that i got this from the Babylon Bee but no, its a function of morons.
Good article. It should be noted that some of the these fluorocarbon materials are relatively inert solids. Teflon polymers and their derivatives are one example. The bad actors are the small molecules which can and do spread in the water table and leach out of products.