I urge thoughtful consideration to all theses factors.
The people of the state of Michigan have a right to safe lakes and streams for our water. A potential spill could damage that and the livelihoods of many of us.
Thank you.
Cindy Mason
USACE’s Draft EIS is a mockery of environmental review, systematically ignoring critical construction risks and project impacts that any competent analysis would address. The agency has turned a blind eye to Enbridge’s project modifications and the company’s calculated efforts to circumvent full state analysis, allowing fundamental design elements, environmental consequences, and construction protocols to escape proper scrutiny under the National Environmental Policy Act (NEPA) and other applicable laws.
This rigged process ensures that no federal agency will fulfill its legal duty to thoroughly examine the severe risks and impacts of this project or the viable alternatives to threading oil infrastructure through one of the world’s most precious freshwater ecosystems. USACE has abdicated its responsibility to conduct genuine environmental review, instead providing cover for a project that should never be permitted. The agency must start over with an honest, comprehensive analysis—or reject this dangerous proposal outright.
Allowing an oil tunnel to be built in the Straits of Mackinac would be an unprecedented experiment that endangers the Great Lakes, one of the most sensitive ecosystems in the world. USACE has failed to fully consider all of the following issues as part of its duty under NEPA to protect our natural resources for the public good and benefit.
I. USACE narrowed alternatives analysis fails to include analysis of reasonable alternative methods and locations for transport of oil currently routed through Line 5.
II. Indirect, cumulative, and connected impacts of this project, including climate impacts and related projects along the path of Line 5 were not fully considered, resulting in segmentation of the analysis.
III. USACE failed to thoroughly review the complex geological and hydrogeological conditions in the Straits of Mackinac and require Enbridge to remedy the inadequacy of existing geotechnical studies.
V. USACE failed to thoroughly evaluate the risk of explosion both during construction and during operation once construction is completed.
VI. USACE’s signaled approval fails to consider the full history of environmental and safety violations committed by Enbridge as it considers potential environmental impacts of the project.
Conclusion: USACE Must Reject This Dangerous and Unneeded Proposal
The Great Lakes are not a testing ground for corporate experiments. Enbridge’s proposal is a reckless gamble with 20% of the planet’s freshwater, and USACE’s truncated review greenlights it without the honest scrutiny required. There is no ‘energy emergency’ justifying this risk, but we do face a climate emergency that demands an end to expansions to dangerous fossil fuel infrastructure, like Line 5. USACE must:
-Reject the current EIS as legally and scientifically indefensible.
-Expand the review to fully analyze alternatives, climate impacts, and risks during construction and operation.
-Honor and protect Tribal Treaty rights, avoid the destruction of cultural resources including resting relatives, and avoid the desecration of an Anishinaabe sacred space by rejecting the Line 5 Tunnel Project.
The stakes could not be higher. If USACE refuses to act, it will be complicit in the potential destruction of the Great Lakes and the communities that depend on them.
Please extend the public comments period so that the public has the time to review the DEIS and respond appropriately.
The public comment period was shortened due to the Emergency Executive Order by 30 days however, products are moving through Line 5 presently so how can this fall under an Emergency. Even though it has been deemed an Emergency, it should not diminish the proper studies and even the Army Corps of Engineers has stated that it will not. The public comments are an important part of the environmental study and if they are limited, that does not abide by Army Corps of Engineers own statements nor NEPA.
Members of the public, also have disabilities which demand access to be part of the process. Denial of an extension would be a violation of disability access.
Hence, we are looking at 2 major violations if the army Corps does not extend the public comment period.
Please notify the public as soon as possible that you make your decision on an extension which is in everyone’s best interest, including the Army Corps of Engineers as this will limit partial public comments entered and then follow up comments.
Thank you for your time.
Sincerely,
Matthew Borke
Citizens across the region have spoken up–and even protested–against the Line 5 project. Experts have pointed out that Line 5 puts the entire ecology of a large section of the Great Lakes at risk without doing much to even benefit Michiganders, who would be directly impacted by any oil spill. The proposed tunnel looks to be a way for a multinational corporation to continue its “business as usual” while disregarding any responsibility for stewardship of our precious land and water resources or the will of the people who would have to live with any oil spill. This includes not just those living within sight (and smell) of any pipeline rupture, but tens of millions of others who rely on the environment and economy of the Great Lakes.
As a Kalamazoo resident who watched the Enbridge pipeline oil spill into the Kalamazoo River in 2010 in horror and was dismayed by its aftermath, I urge the ACE to please slow down this rushed process and carry out a comprehensive and thoughtful risk assessment. Please listen to citizens who are begging you to reject the manufactured “energy emergency” framing of the issue, when the actual, scientifically demonstrated emergency is the climate emergency that requires us to move away from fossil fuel reliance. Please slow down to reconsider the scientific data, risk assessments, and will of citizens of the region. We are calling, unequivocably, for Line 5 to be shut down.
*how unprecedented the project is
*project’s sub-optimal testing
*applicant’s history of not following through with safety, mitigation and restoration measures or addressing concerns meaningfully
*applicant’s refusal to consider alternatives that move less product or change its route (EIS Appendix E).
Bore sites once every 950′ on average across the Straits (EIS 4-191, fig. 4.14-1), instead of the standard 50-250′, will not properly estimate safety risks involved in drilling through highly fractured bedrock (karst formations, groundwater methane seepage, etc.). Delve Underground’s experts reported this to MDOT in 2021, and O’Mara’s comments in 2023 (in Mattei et al 17-18) second this. The Tunnel Boring Machine’s gas and fracture sensors, grout injectors and fluid shields (EIS 4-190-1, 4-193-4) have not been tested in this particular situation, thus seeming as foolproof as the hull chambers in the Titanic meant to prevent her from sinking.
The “atypical” idea of piping highly combustible material (propane) through the tunnel further exacerbates that risk (Mattei et al 19, paragraph 3). With these combined, MIOSHA procedures (EIS 4-189, last par.) and historic precedents cited in section 3.14.1.2.1 (EIS 3-154, 1st par.) and all of 3.14.2, will not completely apply.
After 1991’s spill in Grand Rapids, MN (EIS 3-159 paragraph 1), the applicant formed a 10-minute rule for addressing ruptures and spills, but “Compliance […] is not subject to any regulatory oversight.” (EIS 3-161, par. 1) There should have been oversight, for example, with the spill near Marshall, MI—operators had assumed a vapor bubble in the works instead of an actual rupture (EIS 3-159, par. 2). The IEEFA reveals that decisions on repairing leaks following inspections come thoroughly at the applicant’s discretion, and calls even the updated safety system “imperfect” and the lack of oversight “problematic” (Mattei et al 33). Therefore, I have reason to doubt the applicant’s ability to follow the monitoring systems they have in place for methane infiltration, construction fluid leaks, propane leaks, etc., without strict supervision.
Beyond that, despite the applicant’s promised best management practices and mitigation plans (clearing sites only after resident bats raised their young, revegetation, invasive plant removal, various spill plans, monitoring systems, anti-trafficking policies, etc.), much is not guaranteed. Though comparatively small against all pipeline spills, much was lost in the spill near Marshall (EIS 3-159, 3.14.2) including the Zinn family farm, with 5% of diluted bitumen oil remaining on the landscape (Zinn 3). The applicant did not meaningfully address the family’s concerns before the easement (ibid. 14 & 15) and after the spill (ibid. 30 & 31). Recently, the tribes originally consulted as Cooperating Agencies (EIS 1-10), withdrew from the project when their advice was not meaningfully heeded (Gravelle et al). The statement acknowledges that several wetlands (EIS 344-345, Tbl. 3.4-4; 4-49, last par., 4-51 1st sentence) and archaeological sites (EIS 4-89-90, 4.6.3 pars. 1 & 2) within their construction footprint may indeed become damaged beyond repair. No amount of mitigation measures can completely eliminate the risks. Even the animals and plants listed as “possibly, but unlikely” to be harmed in Table 4.5-4 (EIS 4-78-80) are not beyond concern. Also, whitefish in the Great Lakes have endured much stress already with population loss of the chiefest part of the Lakes’ food web, Diporeia (Edlund et al 1, paragraph 2), so a project with constant disturbances (EIS 4-75 paragraph 1) near many spawning beds (EIS 3-66, fig. 3.5-3) would add too much more stress. Many other unanswered questions feed my concerns, including what herbicides might be used in removing invasive species (EIS 4-86-87).
I recall how many people commenting on the June 18 virtual hearing clamored for work and for the propane the lines would provide (EIS 1-16, last paragraph). Regarding employment, it’s projected that at every stage, only 1/8 of the required workers, at most, would be local (EIS F-40, fig. F-9). What drives the latter demand is largely fear of having inadequate, comfortable shelter, reliable cooking, transport, etc., and that renewable alternatives would not compare in price or effectiveness for local weather and temperature. It reflects small-scale a common global desire listed in the IPCC’s 2022 assessment, for reliable services more than particular energy sources (Creutzig et al. 5.1). The applicant’s simplistic demand to transport the same amount of product per day, even during construction, does not address deeper-seated issues of equitably supplying energy to U.P. homes, especially those that still use propane. Public Sector Consultants (PSC) identified 86 supply terminals near Michigan in 2020 (PSC 50), and concluded requiring careful, robust coordination. Reading the Upper Peninsula Energy Task Force’s 2020 assessment, I can suggest focusing on bulk storage and market pricing (PSC 36), revisiting and improving recommendations (UPETF App. V) and the initial propane security plan (U.P. Energy), and exploring renewable alternatives as other countries in similar latitudes have. The IEEFA second this (Mattei et al 49-51)–expanding involved rebate programs sounds worthwhile. Federal executive action can only create so much demand for fossil fuels over time (see tables in Smith). Certainly, estimated costs of this maiden voyage have increased considerably over the permitting process’ course (Mattei et al 16, Table 2).
To conclude, if the tunnel project must proceed exactly as the applicant stated, then they must provide honest, transparent assessments of requirements, risks and demand, and accept oversight to ensure they hold to promised practices, standards and plans. If, however, the applicant insists upon license not to do so, then denying the tunnel and decommissioning the pipeline would relieve them and the Great Lakes of immense burden. Again, I recommend that in the full EIS, the USACE explore all other options, including rejected ones, using extensive, up-to-date information, and thoroughly accept input from all other parties involved and affected.
As a concerned citizen and parent, I write to emphatically urge the Army Corps to reject a rushed approval of the Line 5 Tunnel Project. PLEASE halt all approvals of this project until a full environmental review can completely assess the project’s significant risks to public and planetary health.
As a citizen and Michigan resident, I am appalled by the dubious claims of an “energy emergency” to justify an overly hasty approval of this unnecessary project – a project that threatens the Great Lakes with an oil spill that would be catastrophic for 21% of the world’s fresh water supply and threaten our drinking water, and thus human life, wildlife, and the state’s economy ($82 billion in Michigan wages are tied to the Great Lakes). These claims are fabricated and false; we have a clear abundance of clean, achievable electric energy alternatives before us that do not depend on fossil fuels. (See Project Drawdown’s solutions here for some of these alternatives; many other countries are advancing ahead of the U.S. in pursuing these smarter sources of energy). In addition, as documented in the film Troubled Water, even if a pipeline were needed, there are alternative routes for a pipeline that do not trespass through the Great Lakes, bypassing meaningful consultation with tribal nations and indigenous communities and threatening lives and livelihoods.
As a parent who has been lucky enough to raise two now-grown children in Grand Rapids with regular summer beach trips to Lake Michigan – Ottawa County’s Kirk Park, Saugatuck Dunes State Park, Hoffmaster State Park, Ludington State Park, and various points in northern Michigan — I have felt, like many others, the value of our fresh water not only for our physical health (water IS life, and without it, we cannot survive) but also for our mental and spiritual restoration (the lake restores our souls and reminds us that we are part of something bigger). Anyone who has enjoyed camping, fishing, boating, swimming, or walking along these great waters must know, deep down in their gut, the truth that an oil spill in the Great Lakes would be far worse than the massive 2010 Enbridge oil spill that contaminated a 30-mile stretch of an otherwise healthy Kalamazoo River, making it one of the worst spills of the time (see Kalamazoo River Watershed Council’s account here). If the Line 5 tunnel is approved, such an oil spill in the Great Lakes is not unlikely; for, as many tunnel experts who have reviewed Enbridge’s plans have attested, building a tunnel under the lakebed is exceedingly complicated and technically challenging, especially in an era of well-documented, increasingly unpredictable extreme weather events in the context of climate change. Such an oil spill would decimate bodies and spirits.
Our public health is deeply entwined with planetary health. Fast-tracking this tunnel only makes us more dependent on fossil fuels, which worsens our public health and climate crises. I would ask the Army Corps to take a wise, long-term view and thoroughly evaluate the tunnel project for both its greenhouse gas emissions and health impacts before proceeding. It can be tempting to succumb to the easiest, quickest “fix,” but the proposed Line 5 Tunnel Project only pins us to an unreliable, risky, fossil-fuel-dependent non-solution.
Thank you,
Amy Dunham Strand, Ph.D.
stillstrandedgr@gmail.com
IT IS NOT RISK FREE AND IT IS NOT WORTH THE RISK!
NO PIPELINE SHOULD GO THROUGH THE GREAT LAKES OR MAJOR FRESH WATER WAYS!
YOU CAN FIND A SAFER ALTERNATIVE.