Posted Draft EIS Comments

Please let our nature be.

USACE re: DEIS -Line 5 Oil
Tunnel.
I am Iris Potter, a MI resident who so loves our Great Lakes and The
Straits. Specifically, I love to be at the Straits to swim and relax in the beauty of this place like no other on Earth. We are grateful for it and the plainly wrong tunnel project, will ruin it. Already, the staging for it has taken and ruined spots I love. I lived through the 2010 Enbridge oil spill on Our Kalamazoo, so I know that they cannot be trusted.
—First and foremost, I request an Extension for the Public Comment period from the 30 day to 60 days because this 1000 page document requires extensive review. This energy emergency is just politically motivated and our safety and the Straits are more
important. This tunnel is an incredibly dangerous and destructive project idea that secures Enbridge 99 more years of running oil beneath the straits, risking 84% of
the North America's-1/5 of the world's
surface freshwater--and 40 million people's drinking
water. At immediate risk are 720 miles of shoreline in
Lake Michigan and Lake Huron along with
numerous wetland habitats and shoreline beaches. The
entire Great Lakes watershed will be irrevocably changed
in the likely event of another catastrophic oil spill
were the Line 5 Tunnel project to proceed fall
'25, threatening Lake Trout, White Fish, wildlife
habitats, water sports, tourism, beaches, property values,
etc.
The following address issues within the
DEIS.
-Construction to last 6 years, obstructing traffic
and creating high noise pollutive emmisions on, near
and within the
Lakes.
-Explosion during construction due to
existing methane pockets highly likely putting workers
at risk of injury or
death.
-The DEIS shows that wildlife, wetlands and more will be affected. Having lived through the 2010 Kalamazoo River devastating spill by Enbridge, nothing will grow back to the same and will never even get close. I don’t trust Enbridge or this very risky, never-before-tried project. Experts have weighed in on the
dangers.
-Stranded boring machine (TBM) risk due to malfunctions and inadequate rock core sampling causing liability to MI
taxpayers.
-Lake floor is made up of unconsolidated
sediment, low rock cover, soft silts & clay where 50% of
rock quality is designated very
poor.
- 1.3 miles at the center of the straits
remain untested at the depth of the planned boring.
-Noise and vibration disturbance to habitat
for animal species for at least 2 years of continuous drilling. They Will be Affected and never the
same.
-5 million gallons/day of bentonite
wastewater during construction to sit on surface of
Lake Michigan for years, killing off fisheries.
-Planned permanent destruction of 1-5 acres
of wetland and 19 acres of wildlife habitat.
-Altered hydrology for surface and
groundwater which could affect local well and city water
sources.
-Plans to run additional electrical and
internet utilities alongside Line 5 carry a high explosion
risk.
-We cannot let happen Enbridge's solution for existing dual pipeline
upon completion: "purging, cleaning, and abandoning
in place." This process alone, will potentially or likely cause more toxic
pollution.
-Line 5 will be a stranded asset by
2040 according to
Enbridge -
-This tunnel project has not had a comprehensive risk assessment which puts all Great Lakes life and our climate at
risk.
-Tribal nations have not been deeply consulted and especially, about the cultural resources in and under the lakebed. These are historic and must be preserved under
law. All 12 Federally-recognized Tribes oppose the tunnel.
Please do not issue this permit based on the DEIS findings coupled with the major risk to Pure Michigan.

Iris Potter & Tom Duffield
———
Several Sources:
National Wildlife Federation - Line
5 National Oceanic and Atmospheric
Administration - Largest Oil Spills Affecting U.S. Waters
Since
1969 Graham Sustainability Institute, University
of Michigan - Analysis of Straits of Mackinac Line
5: Worst Case Spill
Scenarios Flow Water Advocates - Enbridge Line 5
Fact
Sheet Detroit Free Press, Study: Proposed Line 5
tunnel in Straits of Mackinac would cause
'detrimental
effects' Geologist and Tunnel Engineering Safety
Expert Brian O'Mara - Proposed tunnel under straits
of mackinac could
explode Detroit News - Deadly Lake Huron Water
Tunnel
Explosion Oil & Water Don't Mix - Red Flags about
the Proposed Enbridge Great Lakes Tunnel
Project Institute for Energy Economics and
Financial Analysis - Enbridge Should consider closing
its old troubled Line 5
pipeline MDT Question on Geotechnical Investigation
Jan
2021 Michigan.gov Michigan Department
of Environment, Great Lakes, and Energy
EGLE• Line 5
Permits US Army Corps of Engineers - Draft
of Environmental Impact
Statement Mike Wilczynski, Senior Geologist, The Michigan Dept of Environmental Quality

No to Enbridge’s Line 5 pipeline

I am writing to oppose the permitting of the Line 5 Tunnel.

I write this comment fully understanding that the framing of the issue before the Army Corps of Engineers inescapably advantages the construction of the Tunnel. The draft EIS stipulates several criteria must be met for alternatives to this project to be considered. The first one gives away the game. (My emphasis added to the first two bullet points.)

Criterion 1. Does the alternative meet the purpose and need? Relevant considerations include:
**Does the alternative provide for transport of pipeline products between the Applicant’s
existing North Straits and Mackinaw Station facilities?**
**Does the alternative approximately maintain Line 5’s existing capacity (annual average of approximately 540,000 bpd)?**
Does the alternative minimize environmental risks and provide for safe transport?

If the terms of this assessment are to determine which option best maintains current operations, from the Upper Peninsula to the Lower at the points listed, matching the current volume of oll products to be transported, then there is really nothing more to consider. The very design of the EIS is bound to ignore the other considerations that render the presence of such a pipeline, in this particular place, whether beneath the straits bed or in the water, dangerous and unsupportable.

Almost all of the objections to the operation of the dual pipelines that currently operate are also valid relative to the tunnel. Granted, putting pipelines into a tunnel rather than leaving them exposed in open water will eliminate the hazard of anchor strikes and the instability produced by the shifting currents of the Straits.

But new technical problems will inevitably arise, starting with the difficulty of accessing any particular area of the pipeline for repairs once it is encased in a tunnel underground (and underwater). Engineering and construction are not 100% failsafe, and the damage that could be caused by pipeline leaks (and outright rupture) is neither minor nor easily remedied if a rupture came to pass.

Enbridge Energy has a terrible track record in terms of their willingness to accept responsibility for proper maintenance and monitoring of their pipelines. Next month, we observe the 15th anniversary of the catastrophic rupture of Line 6B near the Kalamazoo River, so far the worst inland oil “spill” in North America. The damage resulting there was exacerbated by Enbridge’s failure to respond appropriately to the first alerts of trouble with the line. Some of those losses are irreparable, even after a billion dollars spent toward remediation. Nothing in their more recent conduct suggests they have suddenly become more thorough, careful, and responsible. The risk posed by continued operation in any form of Line 5 to the Straits of Mackinac, Lakes Huron and Michigan, the wetlands and coastal areas associated with all, and to all the living beings who depend on these waters for drinking, fishing, recreation, and spiritual and cultural sustenance is simply unsupportable.

The environmental and cultural damage from tunnel construction is also not negligible. Several advocates have pointed out the precarity of at least one plant species, the Michigan monkey flower, which grows in a very limited range near the Straits and the Leelanau Peninsula (the first, of course, very vulnerable to eradication resulting from construction). At least as importantly, proper investigation of the Indigenous cultural legacy recently discovered in the area of the Straits has not yet been done. It is disrespectful in the extreme–and likely yet another violation of treaty rights–to allow construction to proceed before that study has happened.

But the idea that this EIS can be conducted without consideration of the long-term effects of locking us into a new piece of fossil fuel infrastructure expected to convey an average of 540,000 bpd is truly preposterous. If peak oil has not already arrived, it will soon. Energy generation through solar power is now cheaper than any other method, and despite our current global dependence on oil, more and more countries and economies will transition off of fossil fuels. When that day arrives, sooner than later, this monstrosity will become a stranded asset.

In the meantime, continued support of an energy source approaching obsolescence damages our atmosphere, endangers our long-term prospects for survival, and compromises the health of all who must cope with the pollutants generated by every stage of extraction as well as by the growing number of wildfires across our continent resulting from hotter temperatures and climate weirding.

Given the parameters of the EIS, I can understand why the Tribal Nations withdrew from Cooperating Agency status when faced with this process. Writing this public comment seems almost pointless. But I know I join many thousands of other citizens of Michigan and other Great Lakes states in my vehement objections to the hand-waving that is happening through this unduly constrained assessment. We can--we must--find a better way forward than this one that locks in our dependency on fossil fuel products. I sincerely hope that we can do so before any catastrophic rupture of Line 5 at the Straits of Mackinac demonstrates our folly in not seizing our opportunity, indeed in not fulfilling our generational duty, to shut it down sooner.

Line 5 Enbridge Oil does not make sense for Michigan economically or environmentally. Over 95% of the oil will be coming from and returning to Canada. Additionally this line has already leaked 33 times since 1968. We collectively as a state remember the spill of Line 6B and we will never forget the negative impact on people and environment that this spill has continued to cause to the Kalamazoo area. So its hard to take the word of the environmental impact reports they have paid for. A company will always do anything they can to make money. The economic impact and oil this tunnel produces benefits a foreign country/company, it instead poses negative risks for the numerous community’s it flows through. Additionally the risk to the environment and the disregard of Treaty and Indigenous rights is not keeping with the wishes of Michiganders who call this place home.

To start with Line 5 passes through ecologically sensitive ecosystems. The state is home to 21 % of the world’s fresh water. While this is something that should obviously be protected for future generations and to preserve biologically diversity, it also helps create jobs. Any risk to any of these things should be shut down and stopped immediately.

I also object to the use of a 1977 pipeline treaty, which is being used to justify keeping this pipeline open. Additionally Line 5 can and absolutely should be shut down as it does not cause any significant disruption to energy prices.

The Bad River Band also opposes this pipe line, we have a right to respect, respond and follow indigenous sovereignty. Decisions that impact indigenous communities, culturally or environmentally pose an ethical concern and should be taken seriously.

Lastly U of M scientists have proven that any risk of an oil spill for our great lakes would be devastating. All this proves the pipeline should be shut down indefinitely. Im a lifelong resident of Michigan and I do not support this project.

Please see uploaded files.

The Lake Michigan tunnel pipeline is a huge mistake with so many associated hazards to economy, ecosystems, and human health that to approve it will be a gigantic blunder on the part of the USACE! Wm. Neal, geologist

Please allow additional time for the public to read through the extensive amount of technical information provided. The deadline should be pushed back at least two months.

This line needs to be shut down and removed IMMEDIATELY! Who thought it’d be a good idea to leave a tunnel of oil under our lake for 70+ years???

Please find LVD's official Tribal comments attached to this submission.