In early 2025, California lawmakers passed SB 131 to facilitate residential housing development by eliminating environmental review. San Francisco Senator Scott Weiner pushed to expand the bill to include advanced manufacturing, arguing that California had largely been passed over by the 2022 CHIPS and Science Act and the wave of new semiconductor factories that followed. When the bill became law in July, it exempted all advanced manufacturing, including the construction of chip factories, from California Environmental Quality Act (CEQA) review. The law was pushed through quickly at the end of the session, with a promise to clean up its overreach through subsequent legislation.
As the 2026 California legislative session begins, state leaders have a crucial opportunity to fix SB 131 and ensure it encourages responsible environmental review that can guide and protect communities and the environment. As you steward these clean-up efforts, here are six reasons why skipping environmental review for chip manufacturing communities is a mistake.
1. Chipmaking is a Toxic Chemical Industry
Since the earliest days of chip manufacture, many people have believed semiconductor production to be a clean light industry, because the products were fabricated in “clean rooms,” they didn’t drip oil, and the plants were called campuses. In reality, chipmaking is a chemical industry, using a vast mix of carcinogens, reproductive hazards, greenhouse gases, and lethal gases, all of which the producers consider essential to production. But don’t take our word for it. According to the American Chemistry Council (ACC), “it takes no less than 500 highly specialized chemicals to manufacture one semiconductor chip.”[1] Some of the chemicals the ACC features include N-Methylpyrrolidone (NMP), Ethylene Oxide, and per- and polyfluoroalkyl substances (PFAS), also known as the toxic forever chemicals — all of which are linked to cancer, cardiovascular disease, and reproductive disorders.
In the birthplace of the industry, Silicon Valley, local governments recognized the chemical hazards and passed landmark ordinances regulating toxic gases and the storage of hazardous materials to prevent additional harm to public health and the environment.[2] In fact, a major reason fabs moved elsewhere was lower labor costs and looser environmental regulations. While chip fabrication moved abroad, chip design and software development remained, cementing Silicon Valley into what it is today. But the industry also left behind more toxic Superfund sites in Santa Clara than any other county in the US.[3]
Because of workplace exposure to toxic chemicals, employment in the semiconductor industry has led to chronic disease, miscarriage, birth defects, and death in the US and abroad. US workers in Silicon Valley suffered reproductive health problems, including children born with birth defects.[4] In 2018, Samsung admitted its role in 117 deaths and 320 cancer diagnoses among its South Korean employees.[5] The company acknowledged its responsibility for the health impacts suffered by workers’ children. Recent studies of workers in Asia have found increased mortality for some forms of leukemia among female workers.[6] Research conducted last year in Korea demonstrated that a wide variety of hazardous materials affect workers in semiconductor plants today.[7] By studying the available data sheets on chemicals used in semiconductor fabs, researchers have found “significant amounts of carcinogenic, mutagenic, and reproductive toxicant materials.”[8]
2. Chipmakers Use Hundreds of PFAS – Toxic Forever Chemicals Linked to Serious Health Impacts like Cancer
PFAS, also known as toxic forever chemicals, are highly persistent and mobile in the environment, easily traveling through streams, rivers, and other water bodies, including drinking water sources. Because they break down very slowly, PFAS can easily bioaccumulate in human beings, wildlife, and the environment over time. Studies show PFAS are highly toxic and exposure to low levels of PFAS may lead to serious health problems, including cancers, reproductive issues, developmental effects and delays in children, and more.[9]
Chip production involves PFAS in thousands of applications. In the words of the industry’s global association, SEMI, “there are hundreds (if not thousands) of use-cases [of PFAS] that are each repeated thousands of times throughout the individual components and products used in the industry.” “[A]t this time, semiconductor chips and related devices cannot be produced without PFAS being available at multiple points in the supply chain and for multiple use-cases in the supply chain.”[10]
As a result, chip manufacturers dispose of PFAS (largely unregulated and unmonitored) in their air emissions, solid waste, and wastewater. Studies conducted at Cornell University (2021 & 2023) and Nankai University in China show that current methods used to measure PFAS in wastewater miss over 90% of PFAS compounds discharged by semiconductor fabs.[11] A federal Environmental Assessment in 2024 found, “wastewater discharge from semiconductor fabrication facilities presents a substantial risk for PFAS contamination of the environment.”[12]
3. Accidental Leaks of Hazardous Gases are a Threat and a Reality
Chipmakers use extremely hazardous gases, which pose serious health hazards and are essential to wafer fabrication. In 2022, Intel’s Hillsboro plant was fined for releasing acidic gases. The state of Oregon reported, “Even short-term exposure to these chemicals, in high enough concentrations, can cause severe health effects including respiratory damage and irritation and lung edema, skin burns, and eye irritation.”[13] Closer to home, in 2021, phosphine entered the ventilation system of a small Apple Computer fab in Santa Clara, California, triggering the evacuation of 50 employees, and in 2023, Apple exposed residents of a nearby apartment building to unregulated toxic air emissions.[14] A larger leak could have been deadly.
Environmental review is essential to identify if buffer zones are needed around plants and provide communities with the information they need to make risk management decisions.
4. Bringing Chip Manufacturing Back to California Could Undermine the State’s Climate Goals
Like any manufacturing project, semiconductor companies use large amounts of electricity and thus present a familiar challenge to sustainability. But they also contribute directly to climate change by releasing powerful greenhouse gases directly into the atmosphere. In June 2024, before Congress exempted CHIPS projects from environmental review, a federal Environmental Assessment identified fluorinated gases as the industry’s largest direct source of greenhouse gas (GHG) emissions. US chip companies currently release about six million metric tons a year of CO2 equivalent (MMTCO2E). Globally, just 28 of the larger chip companies contribute 18.9 MMTC02E in direct emissions annually.[15]
Fluorinated gases are among the most potent greenhouse gases measured. A single kg of SF6 (sulfur hexafluoride) has the global warming impact of 25,000 kg of CO2. Perfluoromethane, which has a GWP 6,500 times that of CO2, will persist in the atmosphere for 50,000 years. Semiconductor production releases these gases into the environment; the US EPA estimates that 10 to 80% of fluorinated gases pass through the manufacturing process unreacted and are released into the atmosphere.
Consider the impact of a single new chip factory: New York’s environmental review estimates that one new project—Micron Technology—will release nearly 1.1 million metric tons (carbon dioxide equivalent) of greenhouse gases per year.[16] California regulates such emissions once they occur, but in the absence of CEQA review, there needs to be a mechanism to predict and better control those releases when new fabs are proposed. One new semiconductor plant could overwhelm a city’s greenhouse gas reduction goals.
5. CEQA Exemption is Unlikely to Bring Back Chip Megafabs
California leadership exempted chipmakers from CEQA with the hope of bringing manufacturing megaprojects like Taiwan Semiconductor (TSMC) in Phoenix or Micron in New York to our state, but those location decisions had already been made. The semiconductor industry pioneered a global division of labor, in which they place each activity where it is most profitable. Even without megafabs, Silicon Valley is home to America’s most profitable chip-designing companies, including Nvidia, Intel, Apple, Google, and Advanced Micro Devices, while other manufacturers, such as TSMC, Micron, and GlobalFoundries, maintain technical offices there.
But because California rightly expects employers to protect public health and pay workers a living wage, the CEQA exemption is unlikely to pay off. There will probably be no “megafabs” constructed in the Golden State, regardless of the recent policy change. What the CEQA exemption in California will do is leave communities vulnerable to chemical hazards and environmental contamination from small, specialty semiconductor plants. If such niche facilities are proposed, environmental review would ensure that nearby communities and elected representatives areinformed about the chemical risks inherent in semiconductor manufacturing. Providing a vehicle for public input is a critical way to ensure impacted communities can share their concern.
6. California Should Be a National Leader on Environmentally Sound Chip Production, Not Risk Its Environmental Legacy
California made a huge global contribution to the semiconductor industry in the twentieth century – not only in the development of the silicon chip but in the laws and processes that made production safer, thanks to the scrutiny and activism of communities in Silicon Valley in the 1980s and 1990s.[17] But at the federal level, environmental protection is going backwards. The US Congress exempted CHIPS Act recipients from federal environmental review (NEPA),[18] and Pres. Trump has called for revising bedrock environmental laws like the Clean Air Act and the Clean Water Act to facilitate chip production.[19]
Exempting semiconductor manufacturing from CEQA risks abandoning California’s environmental leadership. It undermines accountability and transparency and leaves vulnerable communities without an avenue for public input. In the absence of federal action, California can be a national leader in protecting surrounding communities and ecosystems from PFAS contamination.
Conclusion
Until the California legislature began exempting major development projects from CEQA, the law provided local governments with the tools they needed not only to document environmental impacts, but to regulate them as well. For example, Mountain View, the birthplace of Silicon Valley chipmaking, routinely used CEQA to protect the occupants of new residential and commercial buildings from vapors still rising from groundwater contamination left by the electronics industry decades ago.
California, especially Silicon Valley, leads the world in tech innovation, largely because it has taken steps to offer the environmental quality that attracts tech professionals, not just from other parts of the U.S., but from the entire world. Restoring CEQA will help sustain the state’s global tech leadership and make it possible for our communities to enjoy the prosperity associated with the tech economy, safely.
References
[1] American Chemistry Council. “Semiconductor: Chemistry Critical to National Priorities.” Chemistry Creates, America Competes, 19 Jan. 2025, https://www.americanchemistry.com/chemistry-in-america/chemistry-creates-america-competes/resources/semiconductor-chemistry-critical-to-national-priorities.
[2] Siegel, Lenny, and John Markoff. The High Cost of High Tech: The Dark Side of the Chip. Harper & Row, 1985, pp. 161–77.
[3] Nieves, Evelyn. “The Superfund Sites of Silicon Valley.” The New York Times, 26 Mar. 2018, https://www.nytimes.com/2018/03/26/lens/the-superfund-sites-of-silicon-valley.html.
[4] Calma, Justine. “The Women Who Made America’s Microchips and the Children Who Paid for It.” The Verge, 19 Feb. 19 2025. https://www.theverge.com/features/611297/manufacturing-workers-semiconductor-computer-chip-birth-defect.
[5] Agence France-Presse. “Samsung Electronics Apologises Over Factory Worker Cancer Cases.” Al Jazeera, 23 Nov. 2018, https://www.aljazeera.com/economy/2018/11/23/samsung-electronics-apologises-over-factory-worker-cancer-cases
[6] Lee, Dong-Wook, Sooyoung Cho, and Aesun Shin. “Lymphohematopoietic Cancer Mortality among Korean Semiconductor Manufacturing Workers.” BMC Public Health, vol. 23, 2023, article no. 1473, https://doi.org/10.1186/s12889-023-16325-z
[7] Park, Dong-Uk, et al. “Assessment of Occupational Health Risks for Maintenance Work in Fabrication Facilities: Brief Review and Recommendations.” Safety and Health at Work, vol. 15, 2024, article no. 1, pp. 87–9discharge PFAS (largely unregulated and unmonitored) into5. https://doi.org/10.1016/j.shaw.2023.11.010.
[8] Yoon, Chungsik, et al. “Chemical Use and Associated Health Concerns in the Semiconductor Manufacturing Industry.” Safety and Health at Work, vol. 11, no. 4, 2020, pp. 500–508, https://www.sciencedirect.com/science/article/pii/S2093791120302717.
[9] Environmental Protection Agency. “Our Current Understanding of the Human Health and Environmental Risks of PFAS.” U.S. Environmental Protection Agency, 5 Nov. 2025, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas.
[10] SEMI PFAS Working Group. PFAS Explainer. SEMI, May 2024, https://www.semi.org/sites/semi.org/files/2024-05/SEMI%20PFAS%20Explainer%20FINAL.pdf.
[11] Jacob, A., et al. “Target and Nontarget Analysis of Per- and Polyfluoroalkyl Substances in Wastewater from Electronics Manufacturing Facilities.” Environmental Science & Technology, 2021, https://chipscommunitiesunited.org/wp-content/uploads/2025/12/Jacob-et-alEST-2021-Target-and-nontarget-analysis-of-per-and-polyfluoralkyl-substances-in-wastewater-from-electronics.pdf; Jacob, A., and D. E. Helbling. “Exploring the Evolution of Organofluorine-Containing Compounds during Simulated Photolithography.” Environmental Science & Technology, 2023, https://chipscommunitiesunited.org/wp-content/uploads/2025/12/JacobHelblingEST-2023-Exploring-the-evolution-of-organofluorine-containing-compounds-during-simulated-photolithography.pdf; Qiao, Y., et al. “Nontarget Screening and Occurrence of Per- and Polyfluoroalkyl Substances in Municipal and Industrial Wastewater.” Environmental Science & Technology, 2025, https://chipscommunitiesunited.org/wp-content/uploads/2025/12/Qiao-et-al-2025-nontarget-screeningoccurrence-of-per-and-polyFASs-in-municipal-and-industrialWW.pdf.
[12] US Department of Commerce. Final Programmatic Environmental Assessment for Modernization and Expansion of Existing Semiconductor Fabrication Facilities under the CHIPS Incentives Program. National Institute of Standards and Technology, 28 June 2024, https://www.nist.gov/document/final-pea-modernization-and-expansion-semiconductor-fabs, Appendix C, p. 15.
[13] Oregon Department of Environmental Quality. Air Quality Permit Review for Intel Corporation: Health Risk and Hazard Analysis. State of Oregon, July 2023, https://www.oregon.gov/deq/nr/202307IntelCorporation.pdf.
[14] Owen, Malcolm. “EPA Fines Apple $261,000 to Settle Hazardous Waste Complaint.” AppleInsider, 18 Nov. 2025, https://www.appleinsider.com/articles/25/11/18/epa-files-apple-261000-to-settle-hazardous-waste-complaint.
[15] Hess, Julia Christina, and Anna Semenova. “Semiconductor Emission Explorer: Tracking Greenhouse Gas Emissions from Chip Production (2015–2023).” Interface – Global Chip Dynamics, 17 Mar. 2025, https://www.interface-eu.org/publications/semiconductor-emission-explorer.
[16] Micron Semiconductor Manufacturing Project, Clay, NY Final Environmental Impact Statement. Onondaga County Industrial Development Authority, document no. EISX-006-55-CPO-001, November 2025, https://ongoved.com/micronfeis2025.
[17] Byster, Leslie A., and Ted Smith. “From Grassroots to Global: The Silicon Valley Toxics Coalition’s Milestones in Building a Movement for Corporate Accountability and Sustainability in the High-Tech Industry.” Challenging the Chip: Labor Rights and Environmental Justice in the Global Electronics Industry, edited by Ted Smith, David A. Sonnenfeld, and David Naguib Pellow, Temple University Press, 2008, pp. 111-138.
[18] “S.2228 — 118th Congress: CHIPS for America International Competition Act.” Congress.gov, Library of Congress, https://www.congress.gov/bill/118th-congress/senate-bill/2228. Accessed 13 Jan. 2026.
[19] “Accelerating Federal Permitting of Data Center Infrastructure.” Federal Register, vol. 90, no. 143, 28 July 2025, https://www.federalregister.gov/documents/2025/07/28/2025-14212/accelerating-federal-permitting-of-data-center-infrastructure.
