The $21 Million White Elephant

Q: When is innovation a dumb idea?

A: When it’s answering the wrong question!

The Glan Devon proposal is described as innovative. In some respects that’s true. Using non-recyclable waste (NRW) as a fuel source to dry biosolids and then blending those dried biosolids is not being done anywhere in the world. So, from that perspective it is new and different. What’s more it solves one of the most persistent problems with drying biosolids – it takes a lot of energy. And we all know how expensive energy can be these days – look at your last power bill!

Burning NRW is a clever way of making drying cheaper.

The problem is drying biosolids is not solving the problem from a 2026 perspective. While BYVQ has been working on the economics of removing water, the scientific, regulatory and commercial problem around biosolids changed – the bigger problem is something else: persistent contaminants, particularly PFAS, that ordinary drying does not destroy.

That’s a problem! The Glan Devon biosolids operation is not going to operate tomorrow. Even an approval in the first quarter of 2027 would only start the next stage. A Planning and Environment Court challenge could push that into the second half of 2027. Add roughly twelve months for construction and three months for commissioning and commercial operation is pushing into 2029. That’s six years after the original idea for using a rural block at Glan Devon to process biosolids.

Six years is a long time in the world of biosolids and PFAS.

I started doing some background research to get a feel for the industry. I looked for papers in scientific journals, government regulations and policy documents. I asked what other businesses and other jurisdictions were doing to manage biosolids. I looked for other people turning biosolids into fertiliser. I found a lot of information, a lot of publications and I found other people turning biosolids into fertiliser.

And then I stopped.

There was something else going on. The sort of thing you don’t ordinarily notice when you are doing this sort of research.

The world of biosolids is changing – and that change is happening very very rapidly. It’s changing fast enough that the rate of change stood out. It was remarkable given that for decades biosolid disposal was a pretty conventional business. No real complexity involved. It was simple:

• Treat the wastewater

• Separate liquids from solids (typically in a thickener)

• Truck the solids (the biosolids) off to landfill or agricultural use

• Job done.

And the main concerns were contaminants like metals or bacteria. You sampled and monitored those contaminants and as long as you were careful things worked.

And then came the public awareness around PFAS.

And then came the public awareness around PFAS.

One strand of the modern PFAS story reaches back to 1938, when a DuPont chemist named Roy Plunkett accidentally discovered PTFE. It was later marketed as Teflon. As product development goes there was nothing especially remarkable about it. DuPont built out the product list, established markets, did all the usual things a chemical company does.

To make it, DuPont needed a processing aid. From the early 1950s that aid was perfluorooctanoic acid — PFOA, known inside the company as C8 — manufactured by 3M and used at DuPont's Washington Works plant on the Ohio River at Parkersburg, West Virginia.

What happened next is not disputed history. It is documented in DuPont's own records, which the company was eventually ordered to hand over.

By 1961 DuPont's own toxicologists had found that C8 enlarged the livers of laboratory animals. By the early 1980s the company was measuring C8 in the blood of its own workers, had found it in local drinking water, and knew it was not breaking down. In 1981, after 3M reported birth defects in the offspring of exposed rats, DuPont reviewed pregnancies among women in its Teflon division. Among a small number of births, more than one child was born with a birth defect. DuPont moved the women out of the division.

It did not tell the community. It kept producing.

In 1984 DuPont bought 66 acres from Jim Tennant, a cattle farmer and DuPont employee whose family had held the land for generations. The block became the Dry Run Landfill. It was represented as non-hazardous. Thousands of tonnes of C8-laced sludge went into it. Dry Run Creek ran out of that valley and down through the paddocks where Jim's brother Wilbur grazed his cattle.

In 1998 Wilbur Tennant — his cattle dying, and turned away by local lawyers, vets, doctors and politicians — telephoned an attorney in Cincinnati named Rob Bilott. Bilott had spent his career on the other side of the table, defending chemical companies. He took the case because his grandmother knew the neighbours.

And then all hell broke loose. Not literally, and not quickly. Legal matters tend to be slow and dreary hard work — paperwork, reading, waiting — punctuated by short, sharp periods of high drama.

The Tennant case settled in 2001. But by then Bilott had the documents, and in August 2001 he filed a class action on behalf of roughly 70,000 people in West Virginia and Ohio whose drinking water was contaminated with C8.

That case is Leach v. E.I. du Pont de Nemours. Its 2004 settlement, ratified in February 2005 and valued at around $107.6 million, is the hinge of the whole story:

• $70 million in cash to the class

• filtration systems installed for the six affected water districts

• funding for an independent epidemiological study, the C8 Health Project

• and, critically, DuPont's agreement that it would not contest general causation for any disease an independent science panel found to have a "probable link" to C8

That last term is why everything afterwards happened.

Between August 2005 and August 2006, the C8 Health Project collected blood and health data from 69,030 residents. Then the community waited. For nearly seven years the science panel worked through it, while Bilott carried the professional and financial strain at his firm.

In 2012 the panel reported. It found probable links between C8 and six conditions: kidney cancer, testicular cancer, thyroid disease, ulcerative colitis, pregnancy-induced hypertension and preeclampsia, and high cholesterol.

DuPont did not pay on the basis of those findings.

So Bilott took them to court, one plaintiff at a time. A run of multi-million dollar verdicts followed. In February 2017 DuPont and its spin-off Chemours settled the remaining claims — around 3,550 of them — for $670.7 million.

That story was told in the film Dark Waters, released in 2019. Just seven years ago. And that is about when the rest of the world started hearing about per- and polyfluoroalkyl substances.

In the seven short years since:

• The Australian government settled a class action over PFAS contamination at Oakey, Queensland for $212 million

• US company Tyco settled a PFAS-related case for $17.5 million

• US company Solvay Specialty Polymers paid $393 million for site remediation

• The Australian government settled a second class action covering contaminated sites including Townsville for $132.7 million

• US chemical company 3M agreed to pay up to $12.5 billion to settle claims by public water systems

• Tyco paid a further $750 million in settlement

• US company BASF paid $316.5 million

• And more.

That’s an explosion of legal action all around the same family of chemicals - per- and polyfluoroalkyl substances. And all that litigation, all the settlement payments, and yes, all the health issues, mean people are taking this stuff seriously. Very seriously indeed.

And the science is evolving rapidly. And the regulators are following the science just as rapidly. The entire question of PFAS chemicals, their use (and abuse), management and disposal is an extremely hot topic.

Because these chemicals are tricky. They are persistent, hard to destroy, and some PFAS compounds can transform into other PFAS compounds.

Ten years ago, this was a specialist problem

PFAS in biosolids is not a discovery of the last few years. Researchers were already studying it more than a decade ago. A 2014 field study measured PFAS uptake into wheat grown on biosolids-amended soil, while another 2014 study examined movement into edible crops including radish, celery, tomatoes and peas.[1,2]

But that is the point.

A decade ago this was primarily a specialist environmental research question. Researchers knew PFAS could occur in biosolids and were asking where it went.

It had not yet become one of the central strategic questions confronting wastewater operators deciding what sort of biosolids infrastructure they should build for the next thirty years.

Then the pace picked up. Again.

Five or six years ago, the obvious treatment question was being tested

By 2019 researchers were asking something brutally practical: perhaps existing biosolids treatment already solved the problem. In other words they were hoping that the same processes we used to manage other contaminants in biosolids, the same regulatory systems, would have already controlled the potential environmental and health impact of PFAS

They were hoping heating, composting, thermal hydrolysis or blending would remove PFAS.

The answer was uncomfortable. A study of commercially available biosolids products found the treatments examined did not reduce the underlying PFAA (Perfluoroalkyl Acids ) load. Blending lowered concentrations by dilution; it did not destroy the contaminant mass.[3]

In 2020 an Australian review of international regulation described PFAS in biosolids as a developing management problem and noted that only a relatively small number of countries had begun limiting PFAS in biosolids intended for land application. Australia published PFAS NEMP 2.0 that year.[4]

That is a useful marker.

In 2020 we were still largely working out how serious the biosolids problem was and how it should be regulated.

BYVQ’s basic technological proposition — dry the sludge, make a better physical product and return it to land — still fitted comfortably within the traditional biosolids-management model.

Then the evidence started becoming much harder to ignore.

Four years ago, cumulative loading stopped being an abstract concern

A 2022 field study examined a site with a long history of biosolids application. PFAS concentrations in the soil correlated strongly with historical sludge loading. PFOA and PFOS were detected well below the surface, and PFAS was detected in groundwater beneath the site.[5]

That changed the character of the problem.

PFAS in biosolids was no longer merely:

What concentration is in this batch?

It became:

How much have we put onto this land over decades, what remains in the soil, what moves downward, what enters water, and what happens when we keep applying more?

This is not a problem government regulators were ready to solve. It required new standards, new regulations. It is a fundamentally different risk problem because fertiliser nutrients and persistent contaminants behave differently.

Nitrogen is applied because plants use it and another dose is required later.

PFAS does not politely reset the clock at the end of the growing season.

Three years ago, Queensland was already worrying about the economics

By 2023 the scientific problem had become a commercial and regulatory one here in Queensland. 2023 – the same year BYV purchased their block of land in Glan Devon and planned on mixing biosolids with sawdust in a composting operation.

The Queensland Government's review of the End of Waste framework recorded concern from resource producers about the impact stronger PFAS requirements could have on continued biosolids reuse. Other stakeholders raised the opposite concern: persistent contamination of agricultural soil and waterways and the consequences that could have for landholders.

This is a real and serious problem. We have been using biosolids in agriculture for decades and now, a new risk is emerging.

The Queensland government review explicitly recorded uncertainty and reluctance among producers and users and noted that some were seeking alternative approaches. It also recorded industry concern about the cost of the biosolids code's PFAS testing requirements.[6]

That was 2023.

It is worth holding that date in mind.

BYVQ's proposed plant may not operate until 2029.

Two years ago, the national framework changed

PFAS NEMP 3.0 (National Environmental Management Plan) was agreed in late 2024. Unlike NEMP 2.0, it included specific risk-based criteria for reuse of PFAS-contaminated biosolids, together with new guidance for resource-recovery products and contaminated land.

The Commonwealth describes the NEMP as an adaptive document — deliberately updated as scientific evidence and guidance develop. Version 3.1 has already followed in 2026 after changes to the Australian Drinking Water Guidelines.[7]

Queensland was not waiting for NEMP 3.0 to discover this issue It’s worth remembering that Queensland was where two of the big PFAS-related class actions occurred. Looks like that focused the government’s collective mind.

The Queensland Biosolids End of Waste Code already requires biosolids and receiving-soil characterisation, estimation of post-application soil concentrations and, in relevant circumstances, post-application testing. That is, you check the paddock before you spread the biosolids, estimate the impact of adding the biosolids and then test it once you’ve added them. And, if you want to add more at a later date, you need to do all that testing again. [8]

This is an important transition in regulatory thinking.

The question is moving beyond “is PFOS below a number?”

It is increasingly about the whole contaminant pathway.

Last year, the field evidence kept arriving

A 2025 study sampled ten working farms in the United States, comparing biosolids-treated fields with untreated controls on the same farms.

PFAS concentrations were generally higher in the treated soils. Precursors (compounds capable of transforming into other persistent PFAS) detected in biosolids were absent in the soils in patterns consistent with transformation into terminal compounds, while shorter-chain PFAS were detected in surface waters draining treated land. The results varied considerably between farms — itself an important finding, because source, soil and management history all matter. [9]

Meanwhile the research literature was changing focus. A 2025 critical review of PFAS in wastewater sludge and biosolids found that pyrolysis and hydrothermal treatment had become prominent areas of research. Researchers were increasingly interested not simply in containing PFAS, but in treatments capable of removing it from the biosolids product and ultimately destroying it.[10]

The technical standard was also becoming harder.

Getting PFAS out of the solid phase is not enough. Thermal-treatment research has shown why: fluorinated compounds can move into gas streams or transform into shorter-chain products. The serious question is increasingly whether the process has actually broken the carbon-fluorine system sufficiently to achieve destruction, and whether the fluorine mass balance closes.[11]

That is a very different technical problem from the type of drying BYVQ is proposing for Glan Devon. And it raises a very uncomfortable question:

Does it make sense to spend $21 million on a technology designed around the biosolids problem of yesterday when the plant must operate in the future biosolids world of 2029, 2035 and 2040? A technology that might (if we are generous) satisfy a regulatory framework in 2026. Given how rapidly the science and the regulations are changing, I suspect the sort of drying planned at Glan Devon will simply not be able to deliver.

In 2026, the problem is moving on several fronts at once

Australia now has NEMP 3.1.

The United States EPA released its first dedicated draft PFOA/PFOS sewage-sludge risk assessment in January 2025. The current US administration has criticised some assumptions in that assessment and is reconsidering aspects of the modelling. But that did not make the biosolids issue disappear: in July 2026 EPA issued new draft guidance specifically aimed at reducing PFOA and PFOS risks from biosolids. [12,13]

That is actually revealing. The precise regulatory numbers are contested. The direction of regulatory attention is not.It’s about reducing PFOA and PFOS below their current levels.

New Zealand has moved from guidance to a national wastewater environmental standard for biosolids reuse. Its 2025 rules now explicitly include maximum concentrations for PFOS plus PFHxS and for PFOA, together with treatment grades, application controls and annual records of where and how much biosolids are applied. [14]

Europe is moving on an even broader front. Five European countries proposed a restriction covering PFAS as a class, and in March 2026 the European Chemicals Agency's Risk Assessment Committee supported EU-wide action. The revised European Urban Wastewater Treatment Directive also creates PFAS monitoring obligations, while Germany's existing sewage-sludge regime will sharply restrict soil application from larger wastewater plants from 2029 and require phosphorus recovery instead.[15-17]

And in June 2026 a modelling study asked the logical next question: if decades of sludge application have created a PFAS inventory in soil, how long does it take to disappear after spreading stops? Its modelling projected that substantial fractions of long-chain PFAS could persist for centuries.[18]

Again, nobody should pretend that every model result is the last word.

But look at what has happened to the questions.

• Ten years ago: can PFAS move from biosolids into crops?

• Seven years ago: do ordinary biosolids treatments remove it?

• Four years ago: what happens after decades of land application?

• Two years ago: how should biosolids reuse be constrained nationally?

• Last year: how do precursors transform and how does PFAS move through real farms?

• Now: how do we demonstrate actual destruction, close the fluorine mass balance and design treatment systems around it?

That is research velocity.

The wastewater operators have noticed

The strongest evidence that this is more than an academic fashion is what wastewater utilities are doing with real money.

South East Water's ordinary biosolids application program remained on hold during 2024–25 while it worked through the implications of PFAS NEMP 3.0. At the same time it has been developing PYROCO with RMIT — a pyrolysis process specifically intended to convert biosolids into biochar while destroying PFAS, pathogens, microplastics and pharmaceuticals. A larger pilot is now planned for operation from 2027. [19]

Unitywater spent two years studying its future biosolids options here in South-East Queensland. Its proposed answer is not merely a dryer. The proposed Bioresource Recovery Facility includes drying followed by high-temperature carbonisation. Unitywater specifically identifies destruction of the majority of PFAS and microplastics as a feature of the process, and says its feasibility study compared the facility with current and likely future biosolids disposal costs. [20]

Then there is Black Rock.

In my previous story I discussed how Barwon Water already operates the Australian example that matters most to Glan Devon: a successful large-scale thermal dryer producing a useful biosolids product. It knows that drying works.

Yet for its next major biosolids project it has been looking at conversion into carbon products such as biochar and renewable energy. Having obtained planning and EPA approvals for the Regional Renewable Organics Network, Barwon Water decided in May 2026 not to proceed directly to construction and returned to the market to explore biosolids-treatment technologies again.[21]

Barwon Water has not said PFAS caused that decision, and there is no basis to put those words in its mouth.

The important fact is simpler.

An operator that already knows how to dry biosolids is reconsidering what its next biosolids technology should be.

And last month Water Research Australia made the industry direction explicit. Its new national project is investigating PFAS destruction during production of biosolids-derived biochar because, in its own words, tightening regulation is threatening existing land-application practices and there is increasing interest in methods that destroy rather than remove or concentrate PFAS. Seven Australian water-sector organisations are supporting that work. [22]

That is not a hypothetical future.

That is September 2026.

Now put BYVQ’s Glan Devon proposal beside that

The distinctive innovation at Glan Devon is not a new method for treating persistent contaminants.

It is the Xetrov energy proposition.

Burn NRW. Recover heat. Use that heat to operate a biosolids dryer more cheaply.

There is real engineering logic in that. If thermal energy is one of the major costs of drying, finding a cheap thermal source can improve the economics enormously.

But PFAS does not care how much the heat costs.

The proposed biosolids dryer operates at around 120°C. SARA has already told the applicant exactly what that means. Its June Further Advice Notice says the process can release some PFAS and precursors into the gas phase but does not destroy PFAS. SARA then asks what happens to PFAS in the dryer exhaust, what happens to it in condensate, what concentrations occur in the incoming biosolids and final fertiliser, and what happens when that product is applied to land. SARA also warns that the proposed drying process could leave the fertiliser outside acceptable parameters for its intended agricultural use. [23]

In other words SARA want to see the PFAS mass balance. What comes in, what goes out and in what part of the process.

That is the heart of BYVQ’s Glan Devon problem.

• The dryer can move PFAS between phases.

• Some may remain in the dried solids.

• Some may enter condensate.

• Some species or precursors may enter the air stream.

• Blending with mineral fertiliser can change concentrations.

None of those things is contaminant destruction.

And SARA is already asking BYVQ to account for exactly those pathways.

The regulator has arrived at this problem before the plant has even been approved.

BYVQ is innovating against the wrong constraint

This is why describing Glan Devon simply as an innovative biosolids solution has become increasingly difficult.

The innovation answers this question:

How can we obtain enough cheap heat to make biosolids drying economic?

The emerging industry question is:

How can we recover useful nutrients and resources without continually transferring persistent contaminants back into soils, water and food-production systems?

Those are different problems.

Unitywater's proposed system at least attempts to address both. It dries because water still has to be removed, then carbonises because something must be done to the remaining material and its contaminants.

South East Water is developing pyrolysis for the same broad reason.

WaterRA is now researching how to prove destruction rather than merely disappearance from a test result.

Meanwhile Glan Devon stops at:

dry it → blend it → pelletise it → spread it back onto land.

Its cheap heat may make the dryer cleverer.

It does not move the project into the emerging contaminant-destruction race. It doesn’t explain where the PFAS go.

BYVQ is not backing the wrong horse in that race. It has barely entered the race at all.

That creates scientific risk — and scientific risk becomes economic risk

Nobody knows precisely what Queensland's PFAS rules will say in 2030.

That uncertainty is not comforting for BYVQ. It is the problem.

A $21 million plant needs regulatory and commercial conditions to remain favourable for many years after construction. Yet every important signal around biosolids contaminants is moving.

• Analytical methods are getting better.

• More PFAS and precursor compounds are being considered.

• Long-term fate and cumulative loading are receiving greater attention.

• Health and environmental criteria are being revised.

• Wastewater utilities are changing strategy.

• National and international regulators are adding controls.

• Treatment research is moving towards destruction.

Queensland's own 2023 End of Waste review already recorded concerns that PFAS rules could make beneficial reuse harder and more expensive.[6]

There is no credible reason to build a 20- or 30-year financial case on the assumption that this pressure will reverse. I can’t see governments saying “she’ll be right” while at the same time fighting multi-million dollar litigation against a known risk.

The uncertainty is not if the regulations will tighten, it is how far and how fast they tighten.

A plant does not have to be banned to become stranded

This is where the economics become ugly.

Suppose future rules require more extensive PFAS characterisation.

• Costs rise.

Suppose some incoming biosolids fail tighter acceptance criteria.

• Feedstock falls.

Suppose cumulative soil-loading rules reduce how frequently the product can be applied.

• The accessible land bank shrinks.

Suppose customers become wary of repeatedly applying biosolids-derived fertiliser.

• Product value falls.

Suppose the finished pellets fail a future resource-reuse criterion.

• Material that was supposed to leave Glan Devon as a saleable fertiliser instead requires another management pathway.

None of this requires a government minister to announce a dramatic ban. The dryer can work exactly as designed. The pelletiser can work exactly as designed.

The $21 million plant can still become economically pointless.

That is a stranded asset.

And adding PFAS destruction later is not a software update

There is another reason the risk cannot simply be waved away as something BYVQ can adapt to later.

A dryer is not a carbonisation plant.

Actual high-temperature contaminant treatment brings different residence-time requirements, gas chemistry, destruction verification, air-pollution controls, energy balances, residues, process safety and approvals.

Indeed, the current research is showing how technically difficult genuine PFAS destruction is. Removing PFAS from a solid test sample is not enough if fluorinated compounds simply leave in the gas stream.

So if the regulatory destination becomes demonstrated contaminant destruction, BYVQ cannot turn a knob on the dryer and arrive there. Nor can it simply turn a knob on the Xetrov incinerator – the vortex might generate a lot of heat but using that heat to destroy PFAS is a different question.

It would need another treatment process.

• More capital.

• More engineering.

• More operating cost.

• And another economic case.

So why spend $21 million?

That is now a much harder question than it was when this project was conceived.

The Glan Devon location already builds substantial additional cost into conventional biosolids management. Wet biosolids have to be hauled to the South Burnett. Water has to be evaporated. The solids are processed, blended with purchased mineral nutrients and pelletised. A market then has to be created for the finished product.

The justification is that cheap heat makes the expensive drying step affordable and the fertiliser product creates additional value.

But that whole proposition is being developed while the biosolids industry is confronting a different cost: the cost of contaminants that drying leaves behind.

Why invest $21 million in making yesterday's treatment pathway more efficient when regulators, researchers and major wastewater operators are rapidly investigating what comes after it?

Why commit the capital before BYVQ has even demonstrated what PFAS concentrations will enter the plant, where those compounds will partition through the process, what concentrations will remain in its fertiliser, or what the receiving-land constraints will be?

And why make that bet now, when the plant may not operate until 2029?

2029 is the date that should worry BYVQ

Look backwards from today by the same amount of time.

Go back to 2020 and Australia had just published NEMP 2.0. International biosolids PFAS regulation was still relatively sparse.

Since then we have seen field evidence of long-term soil and groundwater movement, a Queensland End of Waste review identifying commercial uncertainty, NEMP 3.0 with biosolids criteria, NEMP 3.1, a US EPA biosolids-specific risk assessment, a subsequent US risk-reduction guidance process, a new New Zealand national biosolids standard, advancing European PFAS controls, wastewater operators placing conventional reuse on hold, Australian utilities investing in carbonisation, and a national WaterRA project specifically trying to prove PFAS destruction.

That happened in roughly the time between now and the likely start-up of a Glan Devon plant plus only a few years of operation.

Project the same scientific and regulatory velocity forward.

Not every current concern will survive. Some risk models will be revised. Some technologies will fail. Biochar will not automatically win. New approaches will appear.

But it is extremely difficult to look at that history and conclude that the future of biosolids management is simply:

• find cheaper heat, dry harder and spread more efficiently.

The sector is moving towards a much more difficult demand:

• recover the value, but deal with the contaminants as well.

The Glan Devon proposal does not do that.

And if the bet fails, the Glan Devon location keeps the plant

That is the part the community has every right to care about.

BYVQ can take a commercial risk. Investors can price it. Lenders can decline it. Wastewater utilities can choose another contractor. Fertiliser customers can choose another product.

• The people living around Glan Devon cannot diversify their exposure to the site.

• If the technology succeeds, the industrial facility remains there.

• If the economics deteriorate, the facility remains there.

• If regulation overtakes the process, the facility remains there.

• If the intended fertiliser pathway disappears, somebody still has to deal with whatever material is on the site, the processing equipment, the buildings and the land itself.

That raises questions which should be answered before, not after, approval: what is the closure strategy, what financial assurance exists, how would stored or off-specification material be removed, who carries rehabilitation liability, and what happens if the operating company no longer has the money to do it?

A stranded biosolids plant is not just a bad line in somebody's investment portfolio.

It is a physical place.

And that place is Glan Devon.

BYVQ is solving the wrong problem

There is nothing foolish about trying to find a cheaper source of heat.

The mistake is confusing cheaper drying with a solution to the emerging biosolids problem.

The last six years tell a remarkably consistent story. Science has moved from detection to fate, from fate to cumulative exposure, from a handful of compounds to precursors and broader PFAS inventories, and from measuring contamination towards proving destruction. Regulation has followed. Wastewater operators are following. Capital investment is following.

Even the agencies assessing Glan Devon are following.

SARA is already asking BYVQ where the PFAS goes because its proposed process does not destroy it.

Against that background, the biggest risk to Glan Devon may not be that the proposed dryer fails.

It may work perfectly.

The NRW may burn.

The heat may be cheap.

The water may evaporate.

The pellets may come off the line exactly as intended.

And BYVQ may still discover that it spent $21 million solving the wrong problem.

Postscript

There is another possible future. Governments could attack PFAS primarily at source, progressively eliminating PFAS-containing products and reducing the amount entering wastewater. Stopping PFAS at source may ultimately be the best answer. But history suggests that eliminating a deeply embedded family of useful chemicals is measured in decades, not regulatory announcements. The CFC transition took roughly a generation from scientific alarm to the disappearance of its hardest essential uses. PFAS is embedded far more widely across modern technology. [25]

Even then, source control has a lag. Products already in use remain in circulation, legacy contamination remains in the environment, and Australia is presently regulating selected PFAS while still determining the use of hundreds of others. Nobody yet knows whether source control will reduce biosolids contamination far enough, or quickly enough, to preserve conventional land application over the commercial life of a plant beginning operation around 2029. [24]

References

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[12] US EPA (2025). Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS). Source

[13] US EPA (2026). Draft guidance for reducing risk from PFOA and PFOS in biosolids. Source

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[16] European Union (2024). Directive (EU) 2024/3019 concerning urban wastewater treatment (recast), especially Article 21 monitoring provisions. Source

[17] German Federal Ministry for the Environment (2017). Sewage Sludge Ordinance (AbfKlarV): phosphorus recovery and restrictions on soil-related sewage sludge utilisation from 2029. Source

[18] Kim, M., Hyun, S. & Han, J. (2026). How long will perfluoroalkyl substances persist in sludge-amended soils? Century-scale regional accumulation-decay modeling for North America, Europe, and Asia. Journal of Hazardous Materials, 511, 142251. Source

[19] South East Water (2025). Annual Report 2024-25. See biosolids land-application hold and PYROCO development. Source

[20] Unitywater (2026). Unitywater transforming waste into value with bioresource recovery facility. Source

[21] Barwon Water (2026). New phase for Regional Renewable Organics Network project. Source

[22] Water Research Australia (2026). WaterRA launches research into PFAS destruction during the production of biosolids-derived biochar, 6 August 2026. Source

[23] State Assessment and Referral Agency (2026). Further Advice Notice, referral 2603-51145 SRA, Glan Devon Bio-Fertiliser Facility, 2 June 2026. Source

[24] Australian Industrial Chemicals Introduction Scheme (2025). Information required on introduction of per- and poly-fluoroalkyl substances (PFAS) in Australia - evaluation of 522 listed PFAS. Source

[25] US EPA (2026). Phaseout of Class I ozone-depleting substances. Source

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