The Boise Precedent

Seven Years of PFAS. Hundreds of Millions of Dollars. The Problem Is Still Not Solved.

Micron's existing semiconductor campus in Boise, Idaho uses the same chemistry planned for Clay, NY. Boise has been dealing with Micron's PFAS wastewater since before the CHIPS Act existed. Every fact below is sourced from public records and local news coverage.

The Infrastructure

Two Treatment Plants. Zero PFAS Removal.

Boise operates two wastewater treatment plants, both of which receive Micron's pretreated industrial discharge:

Lander Street Water Renewal Facility — Built 1950. Design capacity 15 million gallons per day. Discharges to the Boise River at river mile 49.9. Serves approximately 122,600 people.

West Boise Water Renewal Facility — Built 1975. Maximum capacity 40 MGD, average flow 18 MGD. Discharges to the Boise River at river mile 43.5. Serves approximately 148,300 people.

Both plants use conventional activated sludge with Enhanced Biological Nutrient Removal (EBNR) and UV disinfection. Neither plant has any PFAS treatment capability. No granular activated carbon for PFAS. No ion exchange. No reverse osmosis. No destruction technology. PFAS that enters the system passes straight through — into the Boise River and into biosolids.

Sources: EPA NPDES permits #ID0020443 and #ID0023981; City of Boise Water Renewal Services; West Boise WRF Virtual Tour

The Timeline: 2014–2026

Twelve Years of Promises, Testing, and Political Fallout

2014
The Secret Contract

The City of Boise signed a 25-year, $50,000/year contract with the Farmer's Union Ditch Company to divert treated wastewater — including Micron's discharge — into an irrigation canal instead of the Boise River. The stated reason was to avoid new EPA temperature regulations on river discharge. The public was not informed. The canal was used for agriculture, flood irrigation of residential yards, gardening, swimming, and fishing.

2019
Discovery and Revolt

Richard Llewellyn, PhD in Biochemistry and president of the Northwest Neighborhood Association, discovered the contract buried in city budget documents. He raised the alarm about PFAS and other contaminants of emerging concern — chemicals that pass straight through conventional treatment. Community opposition was immediate and sustained.

2020
Packed Public Hearings Force PFAS Testing

The city was forced to pause the canal project and test for PFAS. Testing found 7 types of PFAS in the wastewater system. The city's entire Water Renewal Utility Plan — an $890 million to $1.3 billion, 20-year infrastructure program — was reshaped by the PFAS issue.

2021
Canal Contract Cancelled. $570M Bond Approved.

The city formally cancelled the Farmer's Union Canal contract. The environmental manager publicly acknowledged the trust had been broken. A $570 million water renewal bond was placed before voters and approved in November 2021. The National Water Research Institute was brought in for independent expert oversight.

2022
Micron's $15B Expansion + PFAS Pilot Announced

Micron filed permits for a 4.85 million square foot fab expansion — rivaling the Pentagon. Micron stated "any excess wastewater will be fully treated before being discharged to City's treatment facility." The city announced an Advanced Water Treatment Pilot prioritizing PFAS removal, to be tested on Micron's actual discharge water.

January 2023
Pilot Launches in Shipping Containers

The Advanced Water Treatment Pilot launched in shipping containers in a Micron parking lot, testing reverse osmosis, advanced oxidation, and air scrubbing on 40,000 gallons per day of Micron's actual discharge. The city stated publicly that PFAS removal was the top priority.

2023
PFAS Found in the Boise River

Dr. Douglas Sims of the College of Southern Nevada collected 10 water samples from a three-mile stretch of the Boise River downstream of the city's treatment plants. Five of seven PFAS compounds tested were detected, with three at relatively high levels. This contamination is from Micron's existing R&D facility — not the new high-volume manufacturing fab.

Late 2023
Micron Pulls Out of Joint Treatment Plan

Micron withdrew from the city's joint wastewater treatment plan and decided to build its own on-site infrastructure. The city's environmental manager stated publicly that she had "no insight" into Micron's decision. Micron's spokesperson did not respond to press questions. Micron's excess wastewater continues to discharge to the conventional plants — which have zero PFAS treatment.

Late 2023
Pilot Results: RO Removes PFAS, But Fluoride Is a Problem

Phase 1 results showed the treatment system was highly effective at removing PFAS — levels dropped to undetectable after reverse osmosis. But fluoride remained above the maximum level allowed, requiring membrane changes and chemistry adjustments. The lesson: advanced treatment works for PFAS, but only if designed into the system from the start.

2024
$550M Recycled Water Facility Moves Forward

The city purchased a 76-acre site for $20 million and issued an RFP for a $550 million Recycled Water Facility. It will process 6 million gallons per day of industrial wastewater for reuse or groundwater recharge. Planned opening: 2029.

January 2026
The Fight Continues — Seven Years Later

The Farmer's Union Ditch Company held its first board election since 1984 after shareholders organized to block a new recycled water proposal from the Eagle Sewer District. Seven years after Richard Llewellyn first raised the PFAS alarm, the issue is still driving community conflict in Boise.

The Biosolids Problem

PFAS on 4,225 Acres of Farmland

The City of Boise owns and operates a 4,225-acre farm called Twenty Mile South Farm, approximately 20 miles south of the city. Dewatered biosolids from both Lander Street and West Boise are trucked to this farm and applied as fertilizer for alfalfa, corn, and wheat. Those crops are sold to local farmers and on commodity markets, generating $3 to $4 million annually.

Both treatment plants receive Micron's discharge. Neither removes PFAS. PFAS concentrates in biosolids during treatment. Those biosolids are being spread on 4,225 acres of agricultural land that produces food crops sold to local farmers.

Maine and Connecticut have banned biosolids land application entirely because of PFAS. Michigan and Minnesota have implemented mandatory PFAS testing before land application. Boise has no such requirement.

The parallel to Clay: Sludge from Oak Orchard will be trucked to Metro Syracuse for processing. The county's plan has been to sell dried biosolids as agricultural fertilizer. Once Micron's PFAS enters the system, that fertilizer carries PFAS onto Central New York farmland — unless biosolids from the Oak Orchard system are independently tested before any land application is permitted.

City of Boise, Twenty Mile South Farm
Idaho Business Review, "Where sewage sludge is serious business," July 2018
The Injection Well Permits — Obtained March 25, 2026

What the Idaho Department of Water Resources Documents Show

Clean Water Action's National Water Projects Coordinator filed a public records request with the Idaho Department of Water Resources on March 24, 2026. The documents were received the same day. They reveal a second water management operation at Micron's Boise campus, operating alongside its industrial wastewater discharge to the city treatment plants.

Micron holds two active injection well permits. The wells are used to recharge the Boise aquifer with river water used for on-site cooling. Specifically, Boise River water is routed through a non-contact heat exchanger to cool process equipment — the water never directly contacts process chemicals — then ultra-filtered and injected back into the aquifer at a depth of approximately 1,210 feet. Micron's permit application declares no chemical constituents are added to the water beyond a temperature increase of approximately 25-30 degrees Fahrenheit above ambient.

Permit 63W-156-001: Original well, built 1998. Maximum injection rate 6,000 gallons per minute, continuous, 24 hours per day, 7 days per week. Permit expires March 2028.

Permit 63W-156-002: New well, construction anticipated November 2025. Maximum injection rate 5,000 gallons per minute, continuous. Combined: up to 15.8 million gallons per day injected into the deep aquifer.

The monitoring requirements in both permits cover turbidity, coliform bacteria, and total dissolved solids. Neither permit requires PFAS monitoring of any kind.

A municipal well in the Boise area has shut down due to PFAS contamination in the deep aquifer. Source attribution remains contested — Micron's injection activities, Gowen Field Air Force Base (a documented PFAS contamination site from firefighting foam), and other industrial sources have all been identified as potential contributors. Because neither permit requires PFAS monitoring, the question of whether Micron's cooling water recharge operations are contributing to the contamination cannot currently be answered from the regulatory record. Nobody required the testing. That unanswerability is the issue.

This is not an accusation. It is a documentation of a regulatory gap: a major industrial operation injecting millions of gallons per day into a deep aquifer, in an area with confirmed PFAS contamination in that aquifer, with no requirement to test for PFAS. The same regulatory gap — no PFAS monitoring, no PFAS limits — exists at Oak Orchard. ForeverChemicals CNY is working to close that gap before Micron's Clay facility comes online.

Source: Idaho Department of Water Resources, Injection Well Permits 63W-156-001 and 63W-156-002, obtained via public records request by Clean Water Action, March 25, 2026.
The Bottom Line

What This Means for Central New York

Boise was proactive. They started testing years before the new fab came online. They brought in national experts. They passed a $570 million bond. They built a pilot treatment system. They are spending $550 million on a dedicated recycled water facility.

And PFAS is still in the Boise River. PFAS is still on 4,225 acres of farmland. Micron walked away from the joint treatment plan. And the community has been in open political conflict for seven years.

Clay, New York has not started any of this. The Industrial Treatment Plant for Oak Orchard has not been designed. The bond authorizing its construction has not been voted. NYSDEC signed the SPDES permit on April 10, 2026 with zero enforceable PFAS discharge limits. And the county is being told by Micron that the wastewater will be “treatable.”

The bond vote is the leverage point that remains. The Onondaga County Legislature has not yet authorized bonds for the Industrial Treatment Plant. Once that bond is authorized and the design-build contract is awarded, the community loses its best opportunity to require PFAS destruction technology, full chemical disclosure, and enforceable limits in Micron’s Industrial Wastewater Discharge Permit. The window is now.

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