Name
Julie Geisinger
Organization/Affiliation
Entry Date
June 27, 2025 11:16 am
Attachment
Comments
As a lifelong Michigander, I am deeply concerned about Line 5 and the proposed oil tunnel beneath the Straits of Mackinac. The draft EIS confirms that the proposed Enbridge oil tunnel project is risky. Among these findings, the proposed tunnel poses an explosion risk in the Great Lakes, threatens our drinking water, and destroys wetlands and vital habitat to endangered species.
Explosion Risk
Enbridge has significantly changed the project’s design to cut costs. The previous risk assessment for the initial design is now invalid. The previous risk assessment warned that a poor geotechnical study was the greatest risk to the project's success. It assumed a thorough geotechnical program and seismic study would be completed, but they were not.
All of this, combined with the presence of submerged methane, make this design incredibly hazardous with its associated risk of explosion. The risk does not stop there. Once in operation, the explosive nature of natural gas liquids makes transporting them in an enclosed structure quite dangerous. An explosion would spell catastrophe for the Great Lakes.
Threat to Drinking Water
Line 5’s aging infrastructure threatens the Great Lakes and our drinking water. The tunnel is a false solution.
There are several aquifers located in the area Enbridge wants to construct said tunnel. According to the Army Corps findings in the EIS, if tunnel construction moves forward, water resources would experience “direct, detrimental impacts” during the construction process. Furthermore, they state that there is also the “potential for direct, detrimental impacts to groundwater quality, due to a potential release of drilling fluids, a potential release of contaminants associated with onshore material storage, and use of heavy equipment.”
A construction project of this magnitude should not be fast-tracked. Especially when you consider Enbridge’s awful safety record. This includes 33 documented spills along Line 5 alone; the catastrophic oil spill from Line 6B 15 years ago this July in Marshall, MI where nearly one million gallons spilled into the Kalamazoo River; and more recently on Line 6 in Jefferson County, Wisconsin in November 2024 – where Enbridge initially reported a spill of approximately 2 gallons of crude oil, when in actuality it was discovered weeks later that they spilled nearly 70,000 gallons.
In addition to their abysmal safety record operating pipelines, they’ve also had serious missteps during construction. One example is Line 3 in Minnesota, where they breached at least four groundwater aquifers. The State of Minnesota charged Enbridge for failing to report these breaches when they occurred.
Damage to public groundwater resources during tunnel construction in the Straits would be just as likely in Michigan and threatens the drinking water for 40 million people.
Wetlands and Endangered Species
The tunnel project would destroy acres of wetlands and forests, plus threaten endangered species.
The EIS states construction would eliminate summer habitat for 287 potential roost trees used by the endangered Northern long-eared bat and tricolored bat. Other species at risk include the Piping plover, a tiny shore bird that breeds and forages along the shoreline and the Monarch butterfly. Butterflies, larvae and eggs were observed on milkweed plants during surveys in the proposed area.
There are numerous other plant and animal species that are endangered or threatened that could be at risk. Even if they weren’t observed at the survey sites does not mean they aren’t there. Additionally, there are other species that don’t fall under the endangered or threatened category but could still be impacted by tunnel construction or a spill, from migratory birds to fish in the water.
The impact from construction would not be a brief disruption. Construction is anticipated to last at least six years.
Limited Scope
The limited scope the Army Corps. chose to look at for the proposed tunnel is concerning. Furthermore, a construction project of this magnitude should not be fast-tracked.
There was no in-depth study done on the impacts to the environment if there is an explosion or spill during construction or after. It’s especially concerning considering the current Line 5 pipelines will continue to operate in close proximity during tunnel construction should the project proceed.
The importance of the Great Lakes cannot be understated. We’re talking about 21% of the world’s surface fresh water and 90% of the fresh water in the United States, and fresh drinking water for about 40 million people.
Furthermore, the fact this EIS did not look at the entire Line 5 oil pipeline is disappointing. This segmented scope does not look at the big picture. Line 5 is a 645-mile aging pipeline with 33 documented spills.
Additionally, climate impacts were not included in the limited scope. Building any new fossil fuel infrastructure is pure negligence during a climate crisis. It is estimated this proposed tunnel would add 27 million metric tons of polluting and climate altering carbon into the atmosphere. This is the equivalent to 10 coal-fired power plants.
Reject the Tunnel Permit
The tunnel is a false solution. Our Great Lakes deserve better. I urge the U.S. Army Corp to deny Enbridge the tunnel permit.
Explosion Risk
Enbridge has significantly changed the project’s design to cut costs. The previous risk assessment for the initial design is now invalid. The previous risk assessment warned that a poor geotechnical study was the greatest risk to the project's success. It assumed a thorough geotechnical program and seismic study would be completed, but they were not.
All of this, combined with the presence of submerged methane, make this design incredibly hazardous with its associated risk of explosion. The risk does not stop there. Once in operation, the explosive nature of natural gas liquids makes transporting them in an enclosed structure quite dangerous. An explosion would spell catastrophe for the Great Lakes.
Threat to Drinking Water
Line 5’s aging infrastructure threatens the Great Lakes and our drinking water. The tunnel is a false solution.
There are several aquifers located in the area Enbridge wants to construct said tunnel. According to the Army Corps findings in the EIS, if tunnel construction moves forward, water resources would experience “direct, detrimental impacts” during the construction process. Furthermore, they state that there is also the “potential for direct, detrimental impacts to groundwater quality, due to a potential release of drilling fluids, a potential release of contaminants associated with onshore material storage, and use of heavy equipment.”
A construction project of this magnitude should not be fast-tracked. Especially when you consider Enbridge’s awful safety record. This includes 33 documented spills along Line 5 alone; the catastrophic oil spill from Line 6B 15 years ago this July in Marshall, MI where nearly one million gallons spilled into the Kalamazoo River; and more recently on Line 6 in Jefferson County, Wisconsin in November 2024 – where Enbridge initially reported a spill of approximately 2 gallons of crude oil, when in actuality it was discovered weeks later that they spilled nearly 70,000 gallons.
In addition to their abysmal safety record operating pipelines, they’ve also had serious missteps during construction. One example is Line 3 in Minnesota, where they breached at least four groundwater aquifers. The State of Minnesota charged Enbridge for failing to report these breaches when they occurred.
Damage to public groundwater resources during tunnel construction in the Straits would be just as likely in Michigan and threatens the drinking water for 40 million people.
Wetlands and Endangered Species
The tunnel project would destroy acres of wetlands and forests, plus threaten endangered species.
The EIS states construction would eliminate summer habitat for 287 potential roost trees used by the endangered Northern long-eared bat and tricolored bat. Other species at risk include the Piping plover, a tiny shore bird that breeds and forages along the shoreline and the Monarch butterfly. Butterflies, larvae and eggs were observed on milkweed plants during surveys in the proposed area.
There are numerous other plant and animal species that are endangered or threatened that could be at risk. Even if they weren’t observed at the survey sites does not mean they aren’t there. Additionally, there are other species that don’t fall under the endangered or threatened category but could still be impacted by tunnel construction or a spill, from migratory birds to fish in the water.
The impact from construction would not be a brief disruption. Construction is anticipated to last at least six years.
Limited Scope
The limited scope the Army Corps. chose to look at for the proposed tunnel is concerning. Furthermore, a construction project of this magnitude should not be fast-tracked.
There was no in-depth study done on the impacts to the environment if there is an explosion or spill during construction or after. It’s especially concerning considering the current Line 5 pipelines will continue to operate in close proximity during tunnel construction should the project proceed.
The importance of the Great Lakes cannot be understated. We’re talking about 21% of the world’s surface fresh water and 90% of the fresh water in the United States, and fresh drinking water for about 40 million people.
Furthermore, the fact this EIS did not look at the entire Line 5 oil pipeline is disappointing. This segmented scope does not look at the big picture. Line 5 is a 645-mile aging pipeline with 33 documented spills.
Additionally, climate impacts were not included in the limited scope. Building any new fossil fuel infrastructure is pure negligence during a climate crisis. It is estimated this proposed tunnel would add 27 million metric tons of polluting and climate altering carbon into the atmosphere. This is the equivalent to 10 coal-fired power plants.
Reject the Tunnel Permit
The tunnel is a false solution. Our Great Lakes deserve better. I urge the U.S. Army Corp to deny Enbridge the tunnel permit.
Name
Molly Zink
Organization/Affiliation
N/A
Entry Date
June 27, 2025 11:07 am
Attachment
Comments
Our Great Lakes are the greatest resource of the state of Michigan. Any action that will put this fresh water resource at risk is careless and irresponsible stewardship.
Line five approval should not be allowed to “fast track.”
Line five approval should not be allowed to “fast track.”
Name
Leonard Page
Organization/Affiliation
vice chair straits of mackinac alliance
Entry Date
June 27, 2025 10:55 am
Attachment
Comments
Before the US Army Corp of
Engineers Comment of the Straits of Mackinac Alliance on Line 5
permit June 27,
2025 The Straits of Mackinac Alliance (SMA) is composed of property owners on or near the Straits of Mackinac - the very tip of the spear - when it comes to the impact of a Line 5 spill in the Straits. We are driven by the 2018 report of the Michigan Tech study on the devastating impact of a 2.5 million gallon worst case spill, oiling over 700 miles of
shoreline. We have reviewed the recent draft of the USACE permit approval for the proposed Enbridge tunnel project. We note that USACE has doubled the estimated construction time for this project. The three to four year estimate used by Enbridge and the State of Michigan has now grown to six to eight years. Six to eight years of devastating impact on the waters, fisheries and wetlands at the Straits cannot be justified by the claim that a tunnel would offset this damage over the long term. Even more problematic is the exposure of the current 72 year old twin pipelines in the currents of the Straits over a long construction period - more deterioration, more exposure to back and forth high currents at the bottom of the Straits and more exposure to anchor
drags. But the SMA’s comment here is primarily directed at the finding of any alleged NEED (at least in the USA) for Line 5. That finding has to be based on the need for the 23 million gallons of Alberta shale oil products currently being pumped to refineries in Sarnia, Ontario. But this puts Canada first. When almost 90% of the Line 5 product being pumped is burned in eastern Canada, claiming a USA need for this Alberta oil is just
wrong. About 94% of the volume being pumped in Line 5 goes to Sarnia refineries by means of the current high risk Michigan shortcut. Line 5 has had at least 34 spills – making its risk to the Great Lakes more than mere speculation. A rupture of volatile natural gas liquids inside an enclosed tunnel space or a crude oil leak from an anchor drag during tunnel construction - cannot be ignored. The high risk of a methane explosion during tunnel boring operations also cannot be dismissed as a mere engineering
problem. So just how and where does this alleged NEED exist? Line 5 is operating at a volume of 540,000 barrels a day. Line 5 has about 1,300 barrels a day of propane stripped out at Rapid River in the Upper Peninsula for about 13,000 Yooper customers. But the Michigan UP Energy Task Force Report of 2020 shows that the 1,300 barrels of propane for Rapid River can be supplied by 4-5 propane trucks from the terminal at Superior, Wisconsin or about 2 rail cars per day. The alleged need for propane in the UP can clearly be handled. Enbridge also stresses that the lower peninsula propane users import propane from Sarnia. Put aside the risks of propane imports being affected by a tariff war. It is clear that propane users in the lower can reliably get propane deliveries from within the USA at competitive prices. Most propane suppliers in Michigan have even established back-up USA sources for propane in anticipation of a line 5 rupture or shutdown. There is just no “need” for line 5 propane in
Michigan The other potential justification or need is for deliveries of crude oil to gasoline refineries. Almost every refinery in the USA has several crude oil sources. Line 5 delivers about 30,000 barrels a day of Alberta crude to the Detroit Marathon refinery. This volume is only about 1.5% of Michigan gasoline needs. Marathon has the capacity to refine as much as 130,000 barrels a day. Line 5 is thus not essential for the Detroit Marathon or Michigan’s gasoline needs. This conclusion is decisively resolved by Enbridge’s own expert, Neal Earnest, in pending litigation with the Bad River Band in Wisconsin federal court. Enbridge’s statement to the court was that a line 5 shutdown would mean a price bump of half a cent a gallon at the pump in the states of Michigan and Wisconsin. Such low impact thus also shows there is no need for Line 5 crude oil for Michigan’s gasoline consumers. (The district court’s order of 2018 found Enbridge to be a trespasser on the reservation and ordered removal of line 5 by June 2026. Appeals are pending at the 7th Circuit in Chicago) Again - there is just no “need” for line 5’s crude oil in
Michigan. Over 90% of the line 5’s Alberta shale oil products are for the eastern Canada oil market. Small amounts of Sarnia crude are also delivered to refineries in Toledo, Ohio and New York. Again the relatively small volumes used there to not show NEED –at least as far as the USA is concerned. We suggest Canada’s need for Line 5 shale oil should not be a driving factor in the USACE’s analysis
here. The Straits of Mackinac Alliance therefore requests that the risks of a tunnel and the lack of a real NEED for line 5 in the usa, requires that the proposed permit should be
rejected. Respectfully
submitted, Leonard
Page Vice Chair,
SMA 9482 Page
Road Cheboygan Michigan
49721leonard@thepages.net
Engineers Comment of the Straits of Mackinac Alliance on Line 5
permit June 27,
2025 The Straits of Mackinac Alliance (SMA) is composed of property owners on or near the Straits of Mackinac - the very tip of the spear - when it comes to the impact of a Line 5 spill in the Straits. We are driven by the 2018 report of the Michigan Tech study on the devastating impact of a 2.5 million gallon worst case spill, oiling over 700 miles of
shoreline. We have reviewed the recent draft of the USACE permit approval for the proposed Enbridge tunnel project. We note that USACE has doubled the estimated construction time for this project. The three to four year estimate used by Enbridge and the State of Michigan has now grown to six to eight years. Six to eight years of devastating impact on the waters, fisheries and wetlands at the Straits cannot be justified by the claim that a tunnel would offset this damage over the long term. Even more problematic is the exposure of the current 72 year old twin pipelines in the currents of the Straits over a long construction period - more deterioration, more exposure to back and forth high currents at the bottom of the Straits and more exposure to anchor
drags. But the SMA’s comment here is primarily directed at the finding of any alleged NEED (at least in the USA) for Line 5. That finding has to be based on the need for the 23 million gallons of Alberta shale oil products currently being pumped to refineries in Sarnia, Ontario. But this puts Canada first. When almost 90% of the Line 5 product being pumped is burned in eastern Canada, claiming a USA need for this Alberta oil is just
wrong. About 94% of the volume being pumped in Line 5 goes to Sarnia refineries by means of the current high risk Michigan shortcut. Line 5 has had at least 34 spills – making its risk to the Great Lakes more than mere speculation. A rupture of volatile natural gas liquids inside an enclosed tunnel space or a crude oil leak from an anchor drag during tunnel construction - cannot be ignored. The high risk of a methane explosion during tunnel boring operations also cannot be dismissed as a mere engineering
problem. So just how and where does this alleged NEED exist? Line 5 is operating at a volume of 540,000 barrels a day. Line 5 has about 1,300 barrels a day of propane stripped out at Rapid River in the Upper Peninsula for about 13,000 Yooper customers. But the Michigan UP Energy Task Force Report of 2020 shows that the 1,300 barrels of propane for Rapid River can be supplied by 4-5 propane trucks from the terminal at Superior, Wisconsin or about 2 rail cars per day. The alleged need for propane in the UP can clearly be handled. Enbridge also stresses that the lower peninsula propane users import propane from Sarnia. Put aside the risks of propane imports being affected by a tariff war. It is clear that propane users in the lower can reliably get propane deliveries from within the USA at competitive prices. Most propane suppliers in Michigan have even established back-up USA sources for propane in anticipation of a line 5 rupture or shutdown. There is just no “need” for line 5 propane in
Michigan The other potential justification or need is for deliveries of crude oil to gasoline refineries. Almost every refinery in the USA has several crude oil sources. Line 5 delivers about 30,000 barrels a day of Alberta crude to the Detroit Marathon refinery. This volume is only about 1.5% of Michigan gasoline needs. Marathon has the capacity to refine as much as 130,000 barrels a day. Line 5 is thus not essential for the Detroit Marathon or Michigan’s gasoline needs. This conclusion is decisively resolved by Enbridge’s own expert, Neal Earnest, in pending litigation with the Bad River Band in Wisconsin federal court. Enbridge’s statement to the court was that a line 5 shutdown would mean a price bump of half a cent a gallon at the pump in the states of Michigan and Wisconsin. Such low impact thus also shows there is no need for Line 5 crude oil for Michigan’s gasoline consumers. (The district court’s order of 2018 found Enbridge to be a trespasser on the reservation and ordered removal of line 5 by June 2026. Appeals are pending at the 7th Circuit in Chicago) Again - there is just no “need” for line 5’s crude oil in
Michigan. Over 90% of the line 5’s Alberta shale oil products are for the eastern Canada oil market. Small amounts of Sarnia crude are also delivered to refineries in Toledo, Ohio and New York. Again the relatively small volumes used there to not show NEED –at least as far as the USA is concerned. We suggest Canada’s need for Line 5 shale oil should not be a driving factor in the USACE’s analysis
here. The Straits of Mackinac Alliance therefore requests that the risks of a tunnel and the lack of a real NEED for line 5 in the usa, requires that the proposed permit should be
rejected. Respectfully
submitted, Leonard
Page Vice Chair,
SMA 9482 Page
Road Cheboygan Michigan
49721leonard@thepages.net
Name
Steve Bigard
Organization/Affiliation
BIGARD HUGGARD DRILLING INC
Entry Date
June 27, 2025 10:46 am
Attachment
Comments
Requesting the approval of the proposed Great Lakes Tunnel.
Name
Gregory Carpenter
Organization/Affiliation
Crooked Tree Breadworks
Entry Date
June 27, 2025 10:26 am
Attachment
Comments
Greetings,
Thank you for considering my comments regarding thee Army Corps’ Draft Environmental Impact Statement (DEIS) for Enbridge’s proposed Line 5 tunnel.
I am writing to point out that it is deeply flawed and must be rejected.
It fails to 1)Analyze viable alternatives to the tunnel route 2) Consider cumulative climate impacts 3) Account for geologic and explosion risks 4) Evaluate Enbridge’s track record of spills and violations, which is abysmal. I have no confidence in Enbridge's reporting. Nor am I convinced that this tunnel meets a long term need.
Thank you for your attention to this matter
Thank you for considering my comments regarding thee Army Corps’ Draft Environmental Impact Statement (DEIS) for Enbridge’s proposed Line 5 tunnel.
I am writing to point out that it is deeply flawed and must be rejected.
It fails to 1)Analyze viable alternatives to the tunnel route 2) Consider cumulative climate impacts 3) Account for geologic and explosion risks 4) Evaluate Enbridge’s track record of spills and violations, which is abysmal. I have no confidence in Enbridge's reporting. Nor am I convinced that this tunnel meets a long term need.
Thank you for your attention to this matter
Name
Anonymous Anonymous
Organization/Affiliation
Entry Date
June 27, 2025 9:46 am
Attachment
Comments
The public needs more time to review the draft EIS and make comments.
Name
Lyla Hollis
Organization/Affiliation
Entry Date
June 27, 2025 8:58 am
Attachment
Comments
I am writing to express my strong opposition to the proposed Line 5 Tunnel Project. In a time when climate change is accelerating due to fossil fuel emissions, it is deeply irresponsible to consider constructing a tunnel that would prolong the lifespan of a hazardous crude oil pipeline. A six-year construction project that entrenches fossil fuel infrastructure directly undermines Michigan’s statewide goals to achieve 100% carbon neutrality by 2050.
According to the U.S. Army Corps of Engineers' Draft Environmental Impact Statement (DEIS), the tunnel would take an estimated six to seven years to construct, during which time the existing dual pipelines would remain operational in the Straits of Mackinac—posing a continued risk of rupture in one of the most environmentally sensitive areas in North America. The DEIS acknowledges significant uncertainties and geological concerns about the tunnel boring process, including the risk of encountering unstable bedrock and karst features, which could lead to sinkholes or loss of drilling fluids—endangering both construction workers and the surrounding ecosystem.
Furthermore, the Straits of Mackinac connect Lakes Michigan and Huron and form a vital link in the Great Lakes system, which holds over 20% of the world’s surface freshwater. It is unconscionable to jeopardize this global resource for the short-term benefit of a foreign oil company, particularly when viable alternatives, such as the “No Action” alternative, would better protect the public interest and align with Michigan’s clean energy transition.
The DEIS also notes that the project would result in long-term environmental impacts, including potential harm to aquatic life, wetlands, and air quality during construction. In addition, the process has failed to adequately respect and uphold the rights of Tribal Nations. The Straits are culturally and spiritually significant to Anishinaabe communities, and the current process does not demonstrate meaningful consultation or consent, which violates both treaty obligations and basic principles of environmental justice.
Decommissioning the pipeline, rather than building a tunnel, would not only reduce environmental risk but could also create good-paying jobs in cleanup, infrastructure removal, and the development of renewable energy projects—industries that are aligned with a sustainable future for Michigan and its residents.
I urge the Army Corps to reject the tunnel permit and fully consider the overwhelming evidence—present in the DEIS and beyond—that this project poses serious, long-term risks to our waters, our climate, and the sovereign rights of Indigenous peoples.
Sincerely,
Lyla Hollis
Traverse City, MI
According to the U.S. Army Corps of Engineers' Draft Environmental Impact Statement (DEIS), the tunnel would take an estimated six to seven years to construct, during which time the existing dual pipelines would remain operational in the Straits of Mackinac—posing a continued risk of rupture in one of the most environmentally sensitive areas in North America. The DEIS acknowledges significant uncertainties and geological concerns about the tunnel boring process, including the risk of encountering unstable bedrock and karst features, which could lead to sinkholes or loss of drilling fluids—endangering both construction workers and the surrounding ecosystem.
Furthermore, the Straits of Mackinac connect Lakes Michigan and Huron and form a vital link in the Great Lakes system, which holds over 20% of the world’s surface freshwater. It is unconscionable to jeopardize this global resource for the short-term benefit of a foreign oil company, particularly when viable alternatives, such as the “No Action” alternative, would better protect the public interest and align with Michigan’s clean energy transition.
The DEIS also notes that the project would result in long-term environmental impacts, including potential harm to aquatic life, wetlands, and air quality during construction. In addition, the process has failed to adequately respect and uphold the rights of Tribal Nations. The Straits are culturally and spiritually significant to Anishinaabe communities, and the current process does not demonstrate meaningful consultation or consent, which violates both treaty obligations and basic principles of environmental justice.
Decommissioning the pipeline, rather than building a tunnel, would not only reduce environmental risk but could also create good-paying jobs in cleanup, infrastructure removal, and the development of renewable energy projects—industries that are aligned with a sustainable future for Michigan and its residents.
I urge the Army Corps to reject the tunnel permit and fully consider the overwhelming evidence—present in the DEIS and beyond—that this project poses serious, long-term risks to our waters, our climate, and the sovereign rights of Indigenous peoples.
Sincerely,
Lyla Hollis
Traverse City, MI
Name
Nate Rauh-Bieri
Organization/Affiliation
Entry Date
June 27, 2025 8:38 am
Attachment
Comments
This tunnel is a band-aid solution. Only removing the tunnel will prevent pollution of our Great Lakes, respect treaty rights, and move us toward a more liveable climate future.
Name
jay anonymous
Organization/Affiliation
Georgia Institute of Technology
Entry Date
June 27, 2025 8:11 am
Attachment
Comments
Several days is not a sufficient window of time for a representative sample of common working people to review and synthesize the meaning of a 1000 page technical document. Please please please consider extending the window of time available for public comment.
Name
Anonymous Anonymous
Organization/Affiliation
Entry Date
June 27, 2025 1:57 am
Attachment
Comments
This comment period is too short for such a long document. I am requesting more time for the public to review and comment on this EIS