This commentary is by Bob Stannard of Manchester, an author, musician and former state legislator and lobbyist. Stannard, who owns a camp on Lake Bomoseen, has been a leading opponent of the use of the chemical ProcellaCOR EC to combat milfoil in the lake.

Per- and polyfluoroalkyl substances (PFAS) are a group of chemicals used to make products that resist heat, stains, grease, oil, and water. Why are Dickโ€™s Sporting Goods, Patagonia, REI and other major companies banning PFAS? PFAS are commonly known as โ€œforeverโ€ chemicals because they break down extremely slowly in the environment and can bioaccumulate. Many have been shown to cause reproductive and developmental effects in humans and can increase the risk of cancers.ย 

Bennington is an example of how PFAS can plague a community. Seven years ago, many wells around former ChemFab factories were found to be contaminated with PFAS. A recent Bennington Banner story said that the DEC has identified a new โ€œzone of concernโ€ โ€” dozens more wells contaminated from an unknown source. Testing and remediation are ongoing. 

According to SaferStates.org, 37 states have introduced and/or adopted policies related to PFAS. Last year, Minnesota Governor Tim Walz signed into law the most comprehensive PFAS policy yet. This law bans intentionally-added PFAS from 13 product categories: carpets, firefighting foam, food packaging, ski wax, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings and upholstered furniture. Related legislation will regulate pesticide products containing intentionally added PFAS. The Minnesota Department of Agriculture completed preliminary screening of pesticide active ingredients and is working on screening inert ingredients. Over 90 active ingredients were identified as PFAS based on the legislationโ€™s definition. Here’s the complete list.

Vermontโ€™s Act 36 also bans PFAS in the first four product categories above, and bills have been introduced to include other categories. Additionally, $3 million was appropriated to the DEC last year for PFAS remediation. You might get the impression that we donโ€™t want PFAs in our stateโ€™s waters, right? Not so fast. 

One of the chemicals on Minnesotaโ€™s PFAS-pesticide list is florpyrauxifen-benzyl, the active ingredient in a product known as ProcellaCOR. You might have heard about ProcellaCOR. Itโ€™s the new and improved herbicide marketed to target the invasive species Eurasian milfoil. As itโ€™s registered by the EPA (not โ€œapprovedโ€), itโ€™s allowed to be used in Vermont to selectively kill โ€œjust milfoil.โ€ (It kills other plants too) 

The EPA allows PFAS to be intentionally added to our waters for the purposes of killing a weed? Itโ€™s complicated. First of all, the EPA registers all sorts of environmental hazards and toxic and carcinogenic chemicals. Last year, ProPublica found that the EPA greenlighted Chevronโ€™s plan to create fuel from discarded plastics. According to ProPublicaโ€™s exposรฉ, โ€œeveryone exposed to the substance continually over a lifetime would be expected to develop cancer. Current and former EPA scientists said that the threat level is unheard of โ€ฆ a million times higher than what the agency usually considers acceptable for new chemicals.โ€ 

Second, there is no universally agreed upon definition of a PFAS. Minnesota came up with a definition for their legislation. Vermont might define these substances slightly differently. The EPA has its own ever-changing list. The active ingredient in ProcellaCOR might or might not be considered a PFAS depending on who you ask and when you ask them. 

The active ingredient is not the only issue. The majority of a pesticideโ€™s volume consists of proprietary inert ingredients. In 2022, the EPA removed 12 chemicals from their list of allowed inert ingredients because, whoops, they were PFAS! This means that prior to 2022, these PFAS were potentially being poured into our lakes. Who knows, though, because the chemical manufacturers donโ€™t have to tell us. Furthermore, some pesticide storage containers have leached PFAS into pesticides.

Like many chemicals that plagued us in the past, florpyrauxifen-benzyl contains fluorine and chlorine atoms bonded to carbon atoms. Does it have the right number of atoms in the right configuration to allow it to persist in the environment, or to bioaccumulate, or to cause ecological or human harm? Who knows? If florpyrauxifen-benzyl breaks down, will the degradates cause these issues? Who knows? Should any of the inert ingredients in the herbicide or storage container or their degradates be considered โ€œforever chemicals?โ€ Who knows?

So, if PFAS are as bad for us and our environment as many conscientious companies and states believe, then why would anyone in Vermont believe it to be a great idea to use ProcellaCOR, a toxic herbicide with a potential PFAS as its main ingredient? Now Iโ€™m sure thereโ€™s a perfectly good explanation โ€” something like the amount of florpyrauxifen-benzyl used in ProcellaCOR isnโ€™t showing any negative effects on the environment or human health. Not yet. But what do we do if down the road we discover that this herbicide formulation does contain a forever chemical, that it does create environmental or human health problems for our stateโ€™s waters? Will it fall on the taxpayers to pay millions again to clean up this mess? 

And why are we using this toxic chemical at all? Weโ€™re using it to kill a weed that we donโ€™t like. A weed thatโ€™s been in Vermont since 1962! Sixty-two years weโ€™ve coexisted with this weed. Milfoil can take over shallow water and be an utter annoyance, but does it really make sense to be banning poorly understood PFAS on one hand while willingly dumping poorly understood fluorinated herbicide concoctions into our lakes with the other? 

Common sense says otherwise.ย 

Pieces contributed by readers and newsmakers. VTDigger strives to publish a variety of views from a broad range of Vermonters.