Greenfield Global Inc. - Environmental Compliance Approval (sewage)

The ministry reviewed all comments received through the ERO and also consulted with Indigenous communities that may be impacted. All comments received were carefully reviewed, and, where appropriate, were considered in the design of sewage works by the applicant’s consultant and in the ministry’s decision on whether or not to proceed with this proposal. Our review is not only based on the materials submitted by the proponent, but also available science and data and the feedback received from Indigenous communities.

The commenters raised the following concerns on the proposal with ministry’s responses.

1. Insufficient consultation with Indigenous communities.

Ministry’s response: Consultation was conducted with the following Indigenous communities:

• Aamjiwnaang First Nation
  • Caldwell First Nation
  • Chippewas of Kettle and Stony Point First Nation
  • Chippewas of the Thames First Nation
  • Walpole Island First Nation
  • Oneida Nation of the Thames First Nation

The Proponent consulted with all of the communities to discuss the details of the project and addressed concerns.

2. Lack of public consultation, not following the Municipality of Chatham-Kent policies and Municipal Act requirements for consultation.

Ministry’s response: According to the Proponent, the public has been informed about the project since 2021. The project has undergone several years of planning, technical studies, and financial reviews. Council provided multiple approvals between 2021 and 2025 to continue engineering design, financial due diligence, and legal structuring.

3. What type of guardrails and processes are in place to ensure all water is properly treated before it leaves the plant? How do we make sure anything draining into the Thames is safe?

Ministry’s response: The proposed facility has been designed as a contained operation with engineered and operational controls to prevent uncontrolled releases to the environment. Feedstocks will be received, stored, transferred, and processed within dedicated tanks, vessels, piping, and process equipment. Liquid feedstocks, process wastewater, digestate, and other contact liquids will be managed within contained systems. Any spill or leakage will be collected and contained in the secondary containment systems. All process wastewater will be pre-treated at the site and then discharged to municipal sanitary sewer for further treatment by the municipal wastewater treatment plant. Only clean stormwater will be discharged from this site. 

For stormwater from the containment area, sampling and testing will be conducted to determine whether the stormwater contains any contaminants. Only tested stormwater with all parameters below the Ministry’s trigger concentration levels can be discharged through the stormwater management system. If any parameters exceed the defined trigger concentration levels, the stormwater inside the containment will be hauled away for offsite disposal (to an approved wastewater treatment facility). Unimpacted stormwater at this site will be treated by two wet ponds to provide enhanced level quality control (80% total suspended solids removal). The final effluent of the two stormwater ponds will be the only discharge from the site to a municipal storm sewer and ultimately to Thames River. 

The approval requires the Proponent to conduct routine inspections, preventative maintenance, and spill response procedures to avoid contaminants getting into stormwater. Even if contaminants enter into stormwater, they are contained in the secondary containment systems and will be detected by sampling and testing required before any discharge. Stormwater is only allowed to discharge to the municipal storm sewer after the testing results confirm that it meets the applicable quality standards outlined in the ECA. Records of sampling, inspections, maintenance, and operational controls will be maintained in accordance with the ECA as well. 

4. Concerns about the potential impacts this proposal could have on local waterways, wetlands, and surrounding ecosystems. If the proposed filtration or mitigation systems fail, there is also a serious risk that untreated contaminants, chemicals, or excess sediment could be released directly into nearby waterways and wetlands. Equipment malfunctions, inadequate maintenance, or system overloads during heavy rainfall events could quickly undermine environmental safeguards and lead to long-lasting ecological damage.

Ministry’s response: It is important to note that all process wastewater at this site is not discharged to the environment. Pre-treatment is provided for the process wastewater and then the pre-treated effluent will be directed to the municipal wastewater treatment plant for further treatment. This sewage ECA only covers stormwater. Secondary containment systems were designed for process areas and process tanks to avoid spill or leakage which prevents contamination to stormwater.  Any contaminated stormwater will be detected by sampling and testing prior to discharge and will be hauled away for offsite treatment. This raised concern doesn’t apply to this proposal for sewage works.

5. The public requested the below requirements to be added into the sewage approval: 

• containment and spill-prevention measures designed so that a tank failure, overflow, or process upset cannot reach the stormwater pond or the roadside ditch untreated
• water quality monitoring of the stormwater discharge, with parameters and limits appropriate to the Thames River as a receiving water, and public reporting of results
• a clear separation between the facility's industrial wastewater stream and its stormwater stream, with documented assurance that organic or process water cannot enter the stormwater system
• a defined response and reporting protocol for any exceedance or release
• the above conditions be enforceable and that monitoring results be made publicly available

Ministry’s response: These requirements were implemented as conditions in the approved sewage ECA.