Posted Draft EIS Comments

Thank you for the opportunity to comment on the Line 5 Tunnel Project Draft Environmental Impact Statement
(EIS). I have specific concerns about the following potential risks presented by the
project:

1. The rock quality designation (RQD) of 25% of the project area is zero (0). The EIS does not address how this very poor quality of rock could affect the construction and/or operation of the tunnel, such as shifting that could result in strain on or breakage of the tunnel. The EIS should address this issue and identify any mitigation that might be used to resolve it, including studies that support the success of that mitigation.

2. The project rests upon the Collingwood Shale natural gas field, which presents potential for gas explosion, particularly during construction. The Lake Huron tunnel explosion (mentioned in the EIS) where 17 workers were killed, comes to mind. The EIS does not mention this potential specific hazard, and it should be assessed and addressed in the context of this project. As with the RQD, the EIS should also identify any mitigation that might be used to resolve potential issues with the Collingwood Shale natural gas field, including studies that support the success of that mitigation. The information in “Table 4.1-3. Incomplete and Unavailable Information” on page 4-4 begins to address this; however, there is no data cited to show the measures introduced as safety measures in that table have been used and proven. If such supporting information is available, the EIS should cite it. If not, the safety measures should be identified as “untested and unproven.”

3. Worldwide, there are almost no oil and gas pipelines in tunnels; therefore, there is no proven success for this approach. In addition, Dynamic Risk assessed risk for this project (cited in the references: Dynamic Risk Assessment Systems, Inc. 2017. Alternatives Analysis for the Straits Pipeline. Final Report. Prepared for the State of Michigan. October 26, 2017), but they do not have a tunnel expert on their staff. Moreover, that analysis assumed very good rock conditions, minimal groundwater inflow, and no presence of toxic gases or methane—none of which are correct. They also assumed that the space between the pipeline and tunnel wall would be backfilled with concrete. Further study should be conducted by world-class tunnel experts, in conjunction with experts in gas and oil pipelines, before approving a project that could potentially spill enormous quantities of oil into the Mackinaw Straits, polluting Lake Michigan and Lake Huron. And the final design should incorporate all the safety features recommended by those experts.

Given these (and other) flaws in the Draft EIS, it is premature to approve this project. Again, thank you for the opportunity to comment.

The original line 5 was installed at a time when the public opinion had little or NO influence on the Environment Impact of long term operation of said line. One or more breeches of the lines that have occurred in the past history is evidence of possible future problems with keeping the lines in service! Any further redevelopment, drilling, clearing of natural areas, construction of tunnels or under water covering of the line 5 is environmentally unacceptable due to any percentage of future possible breeches of the Line 5. The cost of redirecting the line and reconstruction around the Great Lakes of Michigan should be implemented and paid for by Enbridge! Eliminate Line 5 for the benefit of Michiganders and put the burden of maintaining a multi billion dollar Large Oil Corporation distribution method upon the Canadian Governments responsibility.

I urge the Army Corps of Engineers not to grant a permit for Enbridge’s proposed Line 5 Tunnel beneath the Straits of Mackinac.

This project does not serve the long-term common good of the people of Michigan or the Great Lakes region. From a conservative perspective—one that emphasizes the primacy of human communities, moral ecology, and our obligation to steward God's creation—the tunnel represents a continuation of the very economic logic that has eroded our natural, cultural, and civic inheritance.

The Precautionary Principle and Moral Responsibility:
The Great Lakes are a sacred trust. Nearly 20% of the world’s surface freshwater flows through this system. Building a tunnel to carry crude oil beneath such an ecologically sensitive and economically vital waterway—especially one that is aging, unstable, and operated by a foreign company with a poor safety record—is reckless and morally indefensible.

A central failure of the Draft EIS is its narrow scope of analysis, which privileges short-term technical feasibility over long-term resilience and ecological integrity. The notion that a tunnel can contain risk assumes that risk itself can be engineered away. This is a technocratic illusion. A spill or accident—whether during construction, operation, or decommissioning—would jeopardize fisheries, drinking water, tribal lifeways, and the local tourism economy for generations. That is not a hypothetical concern but a real and present danger, especially given the unique hydrology of the Straits, where currents can spread contaminants across vast areas in hours.

Subsidiarity and the Integrity of Place:
This project is being pushed forward by multinational interests with little regard for the desires of local communities, Anishinaabe tribes, or the State of Michigan, which has already ordered the existing Line 5 to be shut down. The Corps should honor the sovereignty of tribal nations and the will of local and state governments rather than default to the interests of international fossil fuel companies.

The people who live here—who fish these waters, drink this water, pray on this land—should not be made to bear the permanent risk so that tar sands oil can be exported abroad. The Corps must ask: who benefits? And who pays the price?

Economic Stewardship vs. Extractive Growth:
This project is justified under the old paradigm of unlimited growth and fossil fuel dependency. But a truly sustainable economy must be rooted in place, in restraint, and in stewardship. Investing billions in infrastructure that deepens our dependency on fossil fuels runs counter to the urgent need to decarbonize our energy systems and build local, regenerative economies.

Of course, our approach must never pit environmental stewardship against economic vitality—but rather insist that the two must be reconciled through forms of development that are place-based, human-scaled, and future-oriented. Michigan and the broader region would be far better served by investment in energy efficiency, clean transit, and local renewable energy production—projects that create good jobs without mortgaging the health of future generations.

Alternative: Decomission:
Let Enbridge decommission Line 5, and let us reimagine our energy infrastructure not as a tool of global throughput, but as a system of local resilience and regional interdependence. The future does not lie in tunnels beneath God's sacred waters—it lies in rebuilding what we’ve lost: trust, balance, and ecological sanity.

Conclusion
The Corps has a solemn duty—not just legal, but moral—to uphold the integrity of the human and natural communities entrusted to its care. Please do not permit this project. The risks are too high, the benefits too narrowly distributed, and the moral vision far too small. We are called to something better.

Sincerely,
Dominic Garzonio
PhD, University of Michigan
Frankfort, MI
dmgarzo@gmail.com
708-890-7038

It is not a good idea to let a company with such a horrible track record for spilling oil build a pipeline around such a vital part of Michigan clean water.

I am sure that you have read the cumulative impact report. Here is a great summary.
"Recreation: “Direct, short-term detrimental impacts” in the area during construction due to noise and damaged
aesthetics. Groundwater: “Direct, detrimental impacts” with the potential for drilling fluids or contaminants to be released as the tunnel is drilled, which could take 6 – 8 months. It could also lower the water level by as much as 2 feet in a 130-foot area. The Army Corps review says the construction contractor would follow a spill plan and monitor wells during construction and for two years after it is
completed. Surface water: “Direct, detrimental impacts” with the potential release of 20,000 gallons of drilling fluid and unintended release of contaminants. The Army Corps says this fluid is mainly water and a type of clay called bentonite, along with “additives such as lubricants or
greases.” Wetlands: “Direct, detrimental impact” with permanent losses of 4.3 acres of wetland and indirect impact of fragmentation of wetland
systems. Habitats: Various “direct, detrimental impacts” due to removal of up to 19 acres of vegetation, which includes 5.2 acres of forested land. Construction noise and vibration could affect wildlife on land and in the water. The potential release of 20,000 gallons of drilling fluids could also affect aquatic
wildlife. Protected species: Loss of 7.7 acres of habitat for the federally endangered northern long-eared bat and tricolored bat, including clearing of 287 roost trees. Enbridge said it wouldn’t clear trees in June or July, when bats have
pups. Cultural resources: “Adverse effects” on archaeological sites, including activities that could remove or destroy archaeological
resources. Geology: Roughly 416,000 bank cubic yards of rock would be excavated and permanently removed. Formations like sinkholes or caves could develop, and vibrations from tunnel drilling may cause the geology in the area to
shift. Transportation & Navigation: “Direct, detrimental effects” with an increase in road traffic and limited obstruction to
navigation. Air Quality: Short-term impacts to local air quality during
construction. Noise & Vibration: “Direct, local detrimental effects” are likely during construction period, with impacts depending on exact location, while vibration levels are not expected to exceed established impact
thresholds. Energy Demand: “No impact” on the local energy grid’s ability to meet demand." https://michiganadvance.com/2025/06/21/a-guide-to-the-federal-review-of-the-line-5-tunnel/v

The pipeline also violates treaty rights. This is against the law of the land and immoral.

What no one talks about is the impact on tourism. Projects typically take 1.5 to 2x as long as expected to complete. So 7 to 10 years of murky water and only 2-3 lanes on the bridge as one lane is filled with construction equipment. The UP will loose billions in tourism dollars over the decade. Yes, it would be nice to run cables through the tunnel, but is doing that worth the damage? I sure do not think so.

I also understand the tunnel will be a stranded asset. I know others will talk about this, so I am not expanding here.

There is talk that the UP needs the propane, but studies have proven this false. It will only impact by a penny a gallon fir a few years. Jobs will only be needed for construction, this is short term, not long term. When looking at the economic impact, you must include the decrease in tourism for the years the tunnel is under construction.

Tribal withdrawal from cooperative partnership in EIS preparation and compilation reveals the dishonorable stand of this applicant. The fact that well substantiated information was consistently ignored and excluded from factual reporting and consideration exposes the weakness of the applicants support. Shame on them and anyone that moves ahead with this negligent EIS.

No line 5!
Clean water is our most valuable resource.
Don't screw us over to make a dollar!

The line 5 tunnel greatly benefits a few rich, uncaring folks hiding behind a corporate shell while endangering the great lakes area and its population for years to come. Enbridge cannot guarantee the absolute safety of the tunnel forever and there is no shortterm savings for gasoline, propane or natural gas that could possibly pay for the unimaginable horror of a leak. Most estimates of savings to consumers from the pipeline are in the pennies per gallon range. Meanwhile, there are other alternatives to endangering the lakes. Line 61 could be expanded to handle additional flow. Gasoline and propane can move by truck and rail. We as a society can make the move to renewable energy sources before there is a true emergency, rather than a bogus energy emergency declared by climate change deniers. Finally, it's time the United States honored its treaties with Native Americans, who are long overdue a place in the decision making process. The line 5 tunnel should not be approved.

Line 5 must be closed for the protection of our environment for those who will live with the adverse consequences of short sighted profiteering resource management.