Ford megasite atop ‘recharge zone’ for underregulated Memphis Sands aquifer 

Ford Motor Co. promises a green future at its Blue Oval campus, where it will produce zero-emissions pickup trucks with advanced batteries. But forthcoming plans and actions in the new year will prove whether the company and the state are committed to protecting the existing environment at the megasite – like the Memphis Sands aquifer beneath it.  

In the aquifer, sheets of clay and water-saturated sands go down 3,500 vertical feet, stacked like a layered cake. But in a thin area stretched between the Mississippi and Kentucky borderlines is an absence of clay near the surface, where rainwater can infiltrate into the ground quickly and directly replenish a water source that more than a million people rely on for drinking water.  

Part of this recharge zone is underneath Ford’s megasite that spans nearly six square miles —almost the same size as downtown Memphis. 

“Right in the middle of Memphis, you’ve got a shallow aquifer below you, then you’ve got the clay layer, then you’ve got the Memphis Sands, so it takes a while for rain to actually help replenish anything,” said Protect Our Aquifer (POA) Executive Director Sarah Houston. 

“Where it’s most helpful is out east in this band of the recharge zone, and those sands are very porous. When water gets in there, it’s going to flow down to the water table much more quickly rather than make its way through silt and clay. The latest studies from the Center for Applied Earth Science and Engineering Research (CAESAR) and some other publications from the United States Geological Survey (USGS) show that the streams are actually going to be where you have your highest rate of recharge,” she said.

Water challenges with impervious surfaces, like parking lots 

Ford’s planned plant is in the town of Stanton where tributaries flow from the Hatchie River just five miles away. Rivers and creeks rise up from higher rainfall, pushing water through their banks and into the aquifer. But if a large campus brings pavement or impervious surfaces, then water from creeks and rainfall can’t penetrate in the ground. That not only means less recharge, but it results in flooding and dirty stormwater that runs off back into creeks and natural areas.

While its ecological integrity is mostly intact, threats already face the Hatchie River – the largest forested floodplain in Tennessee – from decades of tributary alteration. 

 “It’s hard to separate the river from the floodplain and the floodplain from the forest,” said The Nature Conservancy, Tennessee Chapter, Director of Conservation Alex Wyss. “The river comes out of its banks for much of the year and flows through the forest and drops its sediments and nutrients into the forest, and picks up nutrients and sediments and brings them back into the main channel. So, it’s got a very high diversity of fish, mussels, and then supports the tremendous diversity of animal life and plant life in the floodplain forests.” 

“The greatest challenge facing the Hatchie is that many tributaries did not escape channelization, that led to levees, and the straightening of the streams. That’s sort of when – like a rug unravels – when they are channelized, they unravel. It causes changes in the hydrology, which causes changes in the channel itself, and it results in a tremendous amount of sediment material moving downstream and then into the mainstream of the Hatchie.”

According to a Memphis Regional Megasite (MRM) assessment conducted by Tennessee Department of General Services in June, Little and Big Muddy creeks traverse the site and up to 10 wetland areas dot across 3,600-acres. Channelizing, by lining the creeks with concrete for example, would further disturb water both above and underground. 

Ford says the company will do the ‘right thing’ 

General Services reports that developers must get the state to approve how wetlands will be handled. It’s an unpredictable process that could add months or years to project planning, according to the department. However, analysts behind the General Services assessment believe environmental challenges can be overcome. So does Ford. 

When Ford announced its plant, they shared ambitious goals of carbon neutrality in production and a regenerative impact to wetlands through biomimicry – a design approach that integrates facilities as if they are part of the natural habitat. 

In an one-on-one interview with the Tennessee Lookout, Ford’s Global Director of Environmental Quality Office Andy Hobbs shared some potential solutions the company is exploring, such as porous pavement. Through this surfacing technique, water sinks through gaps in this pavement into a containment pond where it is treated before recharging the aquifer. 

“We are absolutely committed to doing the right thing, and recognize the aquifer is one of the most important natural resources in the region,” Hobbs said.

The Tennessee Lookout asked about specifics of how Ford will meet its commitments, such as stormwater mitigation, but Hobbs said his team has not finalized plans and are not releasing the details yet. 

“What I can’t give you is all the final answers, but I will say as part of the wetland protection, as part of giving community and employees access to natural resources on the site, in terms of making sure we are preserving the historic use of the site – it’s positive as opposed to negatively impacting it.” 

Ford has balanced environmental sensitivity and manufacturing at some of its complexes, such as its green retrofit at its factory in Dearborn, Michigan. But until more detailed plans are released in 2022, Ford can only publicly share its aspirations for environmental protection. That includes building an on-site wastewater plant to treat and reuse wastewater for production and conserve freshwater for only people. 

Battery production companies quiet about water use and zone’s susceptibility to contamination

According to the MRM assessment, three existing on-site wells directly draw from the aquifer, and the groundwater will be pumped to a treatment plant that could hold as much as three million gallons a day. It is unclear how the water supply, treatment, storage, and distribution system will be operated and maintained.   

Activities at the Ford plant involve lithium-ion battery manufacturing – which can use large amounts of water depending on the process, especially when recycling batteries. One of the two methods considered for lithium-ion recycling extracts materials from by dissolving the battery in a liquid, according to a Congressional Research Service report on the environmental effects of electrical vehicle batteries. The other technique chemically transforms materials through a kiln or furnace firing process. It uses less water but is typically more energy intensive and can emit more air pollutants.  

Ford is partnering with SK Battery and Redwood Materials at Blue Oval. The Tennessee Lookout contacted both companies multiple times for an interview about their process of battery production and recycling. Questions also explored prevention and containment protocols for lithium-ion and other chemicals in the recycling process – because the recharge zone is susceptible to contamination compared to areas that have a clay layer. The companies did not respond to requests. 

Regulatory and management gaps persist with aquifer management – as shown by the questionable federal permitting for the now halted Byhalia Connection project, which would have carried crude oil over the aquifer. Additionally, the Tennessee Department of Environment and Conservation (TDEC) permitting process for groundwater protection is complicated.   

“There is not a specific TDEC permit for the production or recycling of batteries, per se. There are various permits that could be required by state law and issued by TDEC for environmental protection, but those would be dependent upon the activities involved in the production and/or recycling processes,” said TDEC Communications Director Eric Ward in an email. “We do know the SK Battery facility will utilize groundwater. Although TDEC does not regulate groundwater withdrawals, water wells must be designed and constructed in accordance with TDEC’s design standards.” 

While TDEC does not monitor withdrawals, companies must register with TDEC if more than 10,000 gallons are pulled per day. 

Ford and SK Battery have only applied for one permit so far, which relates to air quality and the construction of an automotive assembly and battery manufacturing plant. TDEC issued the Memphis Regional Megasite a permit three years ago that covers wastewater discharges, and that may be associated with battery production, according to Ward. As for the permits the companies may need in the future, Ward said it would be premature to speculate. 

The new Megasite Authority is subject to TDEC regulation. Through the signing of House Bill 8001, Gov. Bill Lee granted sole power for oversight to an 11-member board of directors; Lee is an ex-officio member and has appointed two members. The other members are appointed by Lt Gov. Randy McNally, Speaker of the House Cameron Sexton and the commissioners of the Tennessee Departments of General Services, Economic and Community Development and Finance and Administration. According to the bill, it gives the directors exclusive authority to regulate land use. It also mandates how directors will need to establish rates and service for a water system but does not specify protection or sustainability.  

Lee said he is confident the board will lead with integrity, but others are not so sure.  

“The bill devised by the governor’s administration would create law restricting the public’s ability to inspect any contract or agreement … until after the agreement is signed,” Executive director of the Tennessee Coalition for Open Government Deborah Fisher wrote in a public letter. “While bringing Ford Motor Co. to Tennessee may be a game-changer for economic stimulus in the western part of our state, we don’t need it to be a game-changer for transparency in government. We don’t need a whole new branch of government that can operate without public scrutiny.”