Posted Draft EIS Comments

RE: Public Comment on Draft Environmental Impact Statement (DEIS) for the Great Lakes Tunnel Project
USACE Permit Application Number: LRE-2010-00463-56-A19

To Whom It May Concern:

On behalf of 7th Legacy, LLC, a 100% Native-owned stakeholder facilitation and cultural engagement firm headquartered in Suttons Bay, Michigan, I am writing to offer public comment on the Draft Environmental Impact Statement (DEIS) for the Great Lakes Tunnel Project (GLTP).

From our perspective, the Great Lakes Tunnel Project should be approached and evaluated as an environmental project at its core. The intent to relocate Line 5 into a deep bedrock tunnel beneath the Straits of Mackinac represents not only an infrastructure improvement, but a strategic mitigation effort designed to significantly reduce environmental risk to the Great Lakes. The very design of the GLTP—placing the pipeline in a concrete-lined tunnel, isolated from the waters of the Straits—reflects a long-term investment in environmental protection, risk reduction, and technological innovation.

As a facilitation firm that has worked closely with Tribal Nations and Indigenous community leaders across the region, we at 7th Legacy have seen firsthand the complexity of discussions surrounding the GLTP. We believe it is essential to emphasize that Enbridge has demonstrated a consistent willingness to engage in open dialogue with Tribal Nations since the earliest phases of planning and design. These dialogues, however difficult at times, are essential to addressing intergenerational concerns and cultural perspectives, particularly regarding the sacredness of the Straits of Mackinac and the exercise of tribal sovereignty.

We appreciate that the U.S. Army Corps of Engineers has opened a formal channel for comment on the DEIS and acknowledge the significance of this process in upholding the National Environmental Policy Act (NEPA). As a Native-owned business that contracts with Enbridge in the capacity of a facilitator, we also acknowledge and value the space created for Indigenous voices within this process. Our work has included supporting meaningful engagement between Enbridge and tribal communities in both Michigan and Wisconsin, and we continue to believe that dialogue, not distance, will yield the most durable and culturally responsive outcomes.

We urge the Corps to carefully weigh the risk-reducing environmental benefits of the tunnel in comparison to the no-action alternative, which leaves the existing dual pipelines exposed to water currents, vessel anchors, and external threats. In our view, the proposed tunnel represents an environmental improvement over the status quo—one that aligns with modern safety standards and could coexist with tribal consultation, cultural preservation, and environmental stewardship.

Thank you for your consideration of this comment. We remain committed to supporting open, inclusive, and informed dialogue around the Great Lakes Tunnel Project and appreciate the opportunity to contribute to this important public review.

Sincerely,

Desmond L. Berry
Chief Executive Officer
7th Legacy, LLC

Dear U.S. Army Corps of Engineers,
I am writing to strongly oppose the proposed Line 5 tunnel project beneath the Straits of Mackinac.
As a native Michigander, I have spent my whole life enjoying the beauty and vitality of the Great Lakes. I grew up swimming in these waters and exploring the shores that have shaped generations of life and culture in this state. Today, my children drink clean, fresh water from the watersheds of these same lakes. Unlike many parts of the country plagued by droughts and water scarcity, Michigan has been blessed with abundant, unpolluted water—an irreplaceable resource that sustains not just our families but also one of the most diverse agricultural systems in the United States.
Any continuation of Line 5 threatens all of that. And a tunnel isn’t changing the risk.
Environmental Risks
The Great Lakes supply drinking water for over 40 million people. Scientific models, including research from the University of Michigan, show that a spill from Line 5 could impact over 700 miles of shoreline. Even a minor leak could have catastrophic effects on this interconnected freshwater system. Enbridge’s own track record—at least 29 spills and over 4.5 million liters of oil leaked since 1953—makes it clear that the risk is not theoretical; it is real, and it is unacceptable. Building a tunnel only kicks the can down the road.
Safety and Infrastructure Concerns
The tunnel proposal does not eliminate the risks associated with transporting oil—it only buries them. The 2010 Kalamazoo River spill should have taught us the long-term costs of cleanup, damage to ecosystems, and loss of public trust. The technical challenges of detecting and containing a spill under a lakebed, especially in a tunnel, amplify the risk to an unimaginable scale. Line 5 has been cited as the #1 worst case scenario in a report by the Department of Homeland Security.
Economic and Energy Realities
Enbridge and some political leaders argue that shutting down Line 5 would raise gas prices by a fraction of a cent per gallon. That marginal cost does not justify risking an ecological and economic disaster. Michigan’s future lies not in prolonging fossil fuel dependency, but in engineering bold, safe, and renewable energy solutions that preserve our natural wealth for generations to come.
Legal and Sovereign Rights
This project also disrespects Indigenous sovereignty. The Bad River Band of Lake Superior Chippewa and other tribal nations have expressed strong opposition, citing violations of treaty rights and the failure to adequately consult or protect their lands and waters.
A Call for Responsible Engineering
Engineers are entrusted with a sacred responsibility: to protect life and create resilient systems. You must use your skills not to preserving outdated fossil fuel infrastructure, but to pioneering clean, sustainable alternatives. Our children and grandchildren deserve to inherit a Michigan with clean water, healthy food, and the joy of swimming in the Great Lakes just as I have throughout my life.
Conclusion
I urge the U.S. Army Corps of Engineers to halt the forward movement on this project. This is not just about regulatory compliance—it is about protecting the natural heritage, public health, and future of an entire region. I'm not alone in my concern and priorities. A survey conducted by MSU found that 47% of Michigan residents believe the economic benefits of Line 5 are not worth the environmental risk, with 52% supporting its shutdown and replacement. Listen to the people of our state. We don't need to sacrifice our future to foreign oil interests, or even to short-term profit or expense. Our environment is precious, and burying a pipeline and hoping for the best just isn't going to cut it.
Scientific References and Supporting Studies
• University of Michigan. “More Than 700 Miles of Great Lakes Shoreline Vulnerable to Line 5 Oil Spills.” news.umich.edu
• Environmental Defence. Closing Line 5: Risks, Economics, and Alternatives. environmentaldefence.ca
• National Wildlife Federation. “Blurred Tunnel Vision: Enbridge’s Risky Line 5 Expansions.” blog.nwf.org

Please, please do not go through with this.

To the US Army Corps of Engineers:

Do your job as it should be done. Reject rushed approval of the Line 5 Tunnel.

Our Great Lakes are too important to risk them and the diverse living beings that depend upon them. A full environmental study must be completed. This is a process that cannot be rushed.

Thank you for thoughtfully moving forward on this review.

Kate

I have lived in Michigan for over 50 years. One of the best things about living here is that we are surrounded by the Great Lakes, the largest reservoir of fresh water in the entire world. All of us must ensure that the Lakes are protected so that future generations can continue to enjoy this tremendous natural resource. That is why I want Enbridge Line 5 to be shut down. Enbridge is responsible not only for the Kalamazoo River disaster, the largest inland oil spill in US history, but also the largest oil spill in Wisconsin history in Jefferson County. How can we trust this company to care for the Great Lakes when they have been so cavalier about safety in the past? Research done by David Schwab at the University of Michigan shows that an oil spill in the Straits of Makinac, where part of Line 5 currently resides, would be disastrous, due to powerful currents that would make a spill very difficult to clean up. A study done by Robert Richardson at Michigan State University states that a spill in the Straits could cause a $45 billion loss in GDP due to disruption of shipping and steel industries, not to mention the loss to the Michigan tourism industry, which relies heavily on the Great Lakes. Line 5 also violates tribal sovereignty. Line 5 runs through many tribal lands, and the tribes have made it clear that they do not want Line 5 anywhere near their lands, and the continued existence of Line 5 is a violation of their treaty rights. If Line 5 were to be shut down, the State of Michigan performed an analysis on alternatives, and found that there were several (alternative modes of transport, utilizing pre-existing infrastructure) which could fulfill gas and oil needs in Michigan and Canada, with a negligible cost to consumers. Line 5 is over 20 years past its expected lifespan, and has had over 25 oil spills in its lifetime. Enbridge has not properly maintained the pipeline, and they cannot be trusted to protect such a treasure as our Great Lakes. Shut down Line 5 as soon as possible - thank you.

RE: Draft Environmental Impact Statement – Enbridge Line 5 Tunnel Project

To Whom It May Concern,

I am writing as a resident of Michigan, a daily consumer of fresh water sourced from the Great Lakes, and a person deeply concerned about the environmental and public safety risks associated with the proposed Enbridge Line 5 Tunnel Project.

The Draft Environmental Impact Statement (DEIS) recognizes the significant scope and potential consequences of this infrastructure project. I urge the Army Corps of Engineers to deny Enbridge’s permit request based on the company’s longstanding and troubling safety record, and the serious threat this project poses to the Great Lakes, our drinking water, and the regional fishery economy.

Enbridge has repeatedly demonstrated that it cannot be trusted to operate safely:

>In 2010, Enbridge’s Line 6B ruptured near Marshall, Michigan, spilling over 800,000 gallons of diluted bitumen into the Kalamazoo River. This disaster became one of the worst inland oil spills in U.S. history and took years and over a billion dollars to remediate.

>In 1991, Enbridge's Line 3 spilled 1.7 million gallons of crude oil in Minnesota — the largest inland oil spill ever recorded in the U.S.

> In 2024, a spill near Cambridge, Wisconsin, released 70,000 gallons of oil, contaminating soil and groundwater.

>Additional fatal incidents, including a 2003 gas explosion in Ontario and a deadly 2019 pipeline rupture in Kentucky, further demonstrate a persistent pattern of operational failure.

Enbridge’s existing Line 5 pipelines, laid under the Straits of Mackinac in 1953, are now more than 70 years old and lie exposed to powerful currents, anchor strikes, and shifting lakebed conditions. The proposed tunnel does not mitigate the real and ongoing risk these pipelines represent while in operation — a disaster here could release oil directly into the heart of the Great Lakes, with catastrophic effects on drinking water, aquatic ecosystems, and tribal treaty rights.

The risks outlined in the DEIS underscore what the public has been saying for years: the Line 5 tunnel is not a solution — it’s an expansion of the problem. I therefore respectfully urge the Corps to deny this permit and recommend that the aging Line 5 pipelines be decommissioned in favor of safer, cleaner alternatives.

Protecting the Great Lakes is a matter of national interest, economic security, and moral responsibility. We cannot afford to gamble with one of the largest freshwater systems on Earth.

Sincerely,
Tamara Bray
Resident of Michigan

We don't need the line 5 tunnel! There are viable alternatives for transporting this oil through other means of transit and existing pipelines that don't cross the Great Lakes. The tunnel has not been thoroughly studied and will cause significant environmental damage.

My name is Tami Renkoski, and I have lived in a Great Lake State most of my life. I am a retired Certified Industrial Hygienist and have spent most of my career working for global environmental engineering firms. I am also a member of the Michigan Sierra Club.

With the world heading into the climate crisis, NOW is the time to stop new fossil fuel infrastructure. We must say NO to the Enbridge Line 5 Tunnel unless we want to accelerate the climate crisis and impact the futures of our children and grandchildren and the health of the Great Lakes States and the planet. Facts to support this alternative and impacts on the climate include:

• Construction of the Tunnel alone would result in 87,000 metric tons of carbon dioxide equivalent emissions (CO2e) (Peter A. Erikson Testimony). Science tells us we need to be at net zero (NO fossil fuel burning) by 2050 if we are to stay below 1.5 degrees Celsius temperature rise.
• Operation of the Tunnel would result in 520 metric tons of CO2e annually (Peter A. Erikson Testimony)
o This is equal to 6 million cars on the road and 10 power plants
o Operation would also result in $1 billion in negative climate impacts annually
• Burning of the fossil fuels transported by the pipeline would result in an estimated 27 million metric tons CO2e annually (Peter A. Erikson Testimony).
• The Keystone XL Pipeline was denied a permit because the climate impacts were unacceptable. We need to do the same for the Enbridge Line 5 Tunnel.
• The Tunnel will cost $500 million to $2 billion dollars to construct, and construction will take at least six years. It would be completed at the very earliest in 2030, which allows for only 20 years of operation before science tells us we should be burning ZERO fossil fuels.
• The climate costs of keeping Line 5 operating and installing the new Tunnel could conservatively generate $41 billion in climate damages between 2027 and 2070 (Dr. Peter A. Erikson Testimony). Other estimates are as high as $160 billion.
• The Tunnel is incompatible with state and international climate goals (IPCC, Paris Agreement and the Michigan Healthy Climate Plan).
• Michigan and the Great Lakes Region are already experiencing climate change induced higher temperatures, greater than average precipitation and more intense precipitation (recent flooding in Detroit and dam failure in Midland). It is projected that climate change from greenhouse gas emissions will cause the following impacts:
o Negative human health effects and increased mortality
o Fish and other wildlife
o Food production and agriculture
o The fishing industry
o Tourism
o Degradation of ecosystems
o More frequent and severe storms
o Increased flooding, erosion and degradation of waterways
o Destruction of coastal habitats
• In fact, the Great Lakes have already warmed more than the global average. Scientists have documented many fish species that have been forced to live in these warmer environments which is reducing their chances of survival. This affects our fish as food sources and our economy as far as tourism is concerned.

Enbridge considers climate change impacts an “extraneous issue” and didn’t even consider a No Action Alternative when they submitted their permit application. With the health and future of Michigan residents on the line, how can this be “extraneous?” How long until all the waters of our precious Great Lakes are covered in a rainbow sheen and our beaches and wildlife covered in black sludge?

I am asking the USACE to consider climate change and greenhouse gas emissions as a significant impact and MPSC to deny the permit to construct the Tunnel. I am also asking the USACE to conduct a comprehensive evaluation using sound risk analyses and to abide by the USACE’s climate change mission statement in conducting this evaluation. The mission statement is to “develop, implement, and assess adjustments or changes in operations and decision environments to enhance resilience or reduce vulnerability of USACE projects, systems and to observed or expected changes in climate.”

We must not allow this Tunnel to be constructed, and we must shut down the entirety of Line 5 as it will put the future of our people and environment at unacceptable risk. We need to stop new fossil fuel infrastructure NOW and transition our society to green energy NOW. Just say NO to the Enbridge Line 5 Tunnel!

I am asking the USACE to consider climate change and greenhouse gas emissions as a significant impact in the EIS and the MPSC to deny the permit to construct the Tunnel. I am also asking the USACE to conduct a comprehensive evaluation using sound risk analyses and to abide by the USACE’s climate change mission statement in conducting this evaluation. The mission statement is to “develop, implement, and assess adjustments or changes in operations and decision environments to enhance resilience or reduce vulnerability of USACE projects, systems and to observed or expected changes in climate.”

We must not allow this Tunnel to be constructed, and we must shut down the entirety of Line 5 as it will put the future of our people and environment at unacceptable risk. We need to stop new fossil fuel infrastructure NOW and transition our society to green energy NOW. Just say NO to the Enbridge Line 5 Tunnel!

The USACE should pause all forward movement on this project until a comprehensive environmental review has been completed.

The line 5 pipeline is not important to US energy, there is no reason to fast track this project. In fact Enbridge has a terrible safety record with over 1000 spills, necessitating more scrutiny not less. The proposed tunnel is dangerous and puts Michigan’s most valuable asset at risk. The Great Lakes have tremendous economic, and ecological value and we cannot put the tourism and fishing industries at risk for the profits on a foreign corporation. These industries support orders of magnitude more jobs than line 5 will even at peak construction, and in the long term the pipeline will only support tens of jobs while risking hundreds of thousands.

Line 5 traversing Lake Michigan / Huron is an accident waiting to happen. I am a very seasoned engineer and I know there are no perfect solutions. Every design choice involves trade-offs and risks. A pipeline transporting oil passing through the Great Lakes creates a risk to the environment that cannot be contained nor remediated. An oil spill would permanently alter the eco system of the lakes and no amount of controls nor monitoring can prevent a spill from happening. No amount of leak or spill is acceptable. Accordingly, there can be no level of acceptable risk in this case. Imagine a leak occurring mid January while the lake is ice covered. What then ?

There is no way not to alter the environment in order to facilitate construction of the line 5 tunnel nor is there an economic benefit that could outweigh the risk of harm.

Line 5 should not be moved to a tunnel. The risk of harm to the lakes presented by the proposed Line 5 tunnel is too great and unacceptable.

The proposal should be denied.