Micron’s NY Semiconductor Complex Must Address Pollution Impacts

Sierra Club’s Atlantic Chapter submits letter during public comment period on megaproject’s DEIS
Contact

Ginny Roscamp, Senior Press Secretary, Federal Communications, Sierra Club, ginny.roscamp@sierraclub.org 

SYRACUSE, NY — The Sierra Club’s Atlantic Chapter is raising concerns about the pollution impacts from Micron’s planned buildout of a massive complex of  four semiconductor fabrication facilities (fabs) in Central New York, detailing its concerns in a 37-page letter submitted to the Onondaga County Office of Economic Development and the U.S. Department of Commerce’s CHIPS Program Office during the comment period for the Draft Environmental Impact Statement (DEIS) for the project. The comment period ended on August 11.

“The semiconductor industry is vital to America’s clean energy economy, but communities deserve to know that economic development won’t come at the cost of their health or environment. Micron’s massive semiconductor complex could present a once-in-a-generation opportunity to learn from the industry’s toxic past and build a project that contributes to a healthy, sustainable, and prosperous future for all,” said Kate Bartholomew, Chair of the Sierra Club’s Atlantic Chapter. “After reviewing the insufficient Draft Environmental Impact Statement, the community is more concerned that Micron’s proposed project will increase harmful air pollution, threaten local wetlands, and spew toxic chemicals into the environment. This is a pivotal moment for New York’s leaders to choose a path forward that protects public health, limits environmental impacts, and sets a new standard for responsible, innovative industry.”

The Sierra Club’s comment letter outlines the following concerns with the DEIS:

  • The unwillingness to consider smaller viable alternatives, such as two or three fabs, rather than four
  • Proposed energy sources that are inconsistent with Micron’s prior commitments to utilize 100% renewable energy in the project
  • Failure to consider the project’s impact on New York’s renewable energy goals and inconsistency with the state’s climate law
  • Flawed calculations that led to understated Scope 2 emissions
  • Insufficient disclosures of Scope 3 emissions and air pollution from the steel and cement used in construction
  • No plan to lower Scope 3 emissions from building materials despite state law and Micron’s prior commitments
  • Failure to adequately identify the chemicals and quantities used in manufacturing, which makes it impossible to examine risks to workers and nearby communities
  • Inadequate discussion of impacts from spills or leaks, although millions of gallons of chemicals will be transported to, and stored at, the site
  • Inadequate detail about the types of PFAS that would be used at the fabs, and false assurance that meeting current regulatory guidelines will protect human health and the environment
  • Lack of clear definitions about the types of waste streams and what could be recycled
  • Lack of information about the makeup and disposal of wastewater sludge and hazardous waste
  • The need for more localized air pollution monitoring to support claims that emissions from construction and operation will not violate national air quality standards, since current estimates are based on a monitoring station 70 miles away
  • The inappropriate use of thermal oxidation (incineration) to treat fluorinated gases, leading to toxic air emissions and the use of large quantities of methane gas
  • Unclear criteria on how nearby wetlands will be identified and which ones will be protected, despite New York’s new and more protective standard

BACKGROUND

In the U.S., the semiconductor industry holds a significant toxic legacy that has impacted both workers’ health and the environment. California’s Santa Clara County — the heart of Silicon Valley — has more Superfund sites than any other county in the U.S. People who worked at semiconductor facilities in the U.S. throughout the second half of the 20th century endured unsafe manufacturing conditions, including exposure to hazardous substances, which contributed to health problems not only in themselves, but also in their children.

​​Micron is the recipient of $5.5 billion from the State of New York and $6.14 billion in public funding from the U.S. Department of Commerce under the CHIPS and Science Act to support the construction of semiconductor “megafabs” in New York and Idaho. 

In April 2024, the Sierra Club and the CHIPS Communities United coalition urged Micron to follow through with its commitments to labor, sustainability, and community benefits outlined in the preliminary agreement with the Department of Commerce. 

In October 2024, Sierra Club led environmental and public health groups to warn former President Biden that without rigorous and transparent environmental review, PFAS “forever chemicals” from semiconductor manufacturing would endanger public health and the environment, contributing to a growing legacy pollution problem and downstream contamination issues — including in New York’s drinking water and farmland

In December 2024, the Sierra Club and the CHIPS Communities United coalition raised concerns about contracts between Micron and the Department of Commerce, including facilities in New York, for the lack of transparent, enforceable commitments to ensure that public funds create good jobs and a clean environment, which was meant to be is a central part of the CHIPS and Science Act and New York’s Green CHIPS Law.

About the Sierra Club

The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. In addition to protecting every person's right to get outdoors and access the healing power of nature, the Sierra Club works to promote clean energy, safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and legal action. For more information, visit www.sierraclub.org.