Posted Draft EIS Comments

The proposal to build a tunnel in the straights of Mackinaw to replace line 5 is dangerous and absurd. The tunnel will take years to build, destroy habitat (trees and wetlands) in order to build, pose dangers to the geology and the environment, and ignore Native treaties. Line 5 is way past it’s 50 year life span. It poses a danger every day to the Great Lakes watershed, animals, people and the economy. There have been numerous oil spills and leaks along Enbridge pipelines. WHY so we want to continue with this company? WHO really is benefiting? Another route for this oil MUST be found! I have lived my whole life (68 years) near the Great Lakes in Michigan. Our country IS NOT in a fossil fuel emergency. I worry that corporate greed and political gain will ruin our beautiful environment for fossil fuel extraction. There are other ways!

The Great Lakes are an extraordinary treasure to Michigan, and their health and safety should be our priority. Studies have indicated the Line 5 tunnel project poses great risk to both environment and workers, an imperative consideration for the project to undergo a much more comprehensive risk assessment than has been done to date. The reckless “fast tracking” of this project is politically motivated, egregiously labeled an energy emergency when in fact the environmental impact and health risks to be assessed first are the highest priority. Consulting with Indigenous communities and First Nations tribes on the Line 5 tunnel must also be sought and honored, as well as public opinion on this matter. Since 2020 when the Michigan governor revoked easement to the contractor Enbridge due to environmental concerns and risks, they continue to operate illegally. For all reasons cited I recommend a much greater expansion of the EIS of the USACE.

Please do not fast track the Line 5 tunnel application process. Too many lives and livelihoods rely on the waters of the Great Lakes! As one of the largest fresh water systems in the world, we cannot survive an accident from Enbridge’s tunnel project or even their Line 5. Please do not let politics interfere with your due diligence!

ENBRIDGE LINE-5 TUNNEL PROJECT

I am a concerned citizen of Michigan. As a native of Detroit, and resident of this beautiful state for most of my adult life, I’m perplexed by why anyone would want to risk destroying the largest source of fresh water on planet Earth.

When this project fails and millions of gallons of crude oil flow directly into the Great Lakes, then what are the plans to restore balance to the natural order that sustains all its associated life forms? Not a single word in the USACE report addresses this. Why?

Why hasn’t the USACE considered building a tunnel to support automobile and other transportation systems along with this pipeline? The Mackinaw Bridge is not going to last forever, and this is a perfect opportunity to integrate this aspect into such an ambitious project. Perhaps no one has informed politicians and oil stake holders that this project carries significant potential environmental impacts and logical consequences.

This project is narrow minded and stands as a perverted symbol of progress, especially since it’s occurring in the 21st Century!
I know this message will never reach those with the money and political power completing this project, but nonetheless, thanks for your consideration.

The Enbridge Line 5 Tunnel EIS is deficient to the point of requiring it to be withdrawn and substantially modified. The Army Corps has improperly limited the scope of the EIS despite extensive comments received during the scoping process. In particular, the project scope has been arbitrarily limited despite prohibitions on segmentation of environmental reviews like this and the several calls in the scoping process to avoid segmentation. Specifically, by choosing solely to review the two sites where the tunnel is proposed to emerge above ground, and failing to consider the increasing environmental threats posed by the 70+ year old, 645 mile long pipeline, the Army Corps has failed in it duties under the National Environmental Protection Act. The failure to simultaneously consider the proposed tunnel under the Straits of Mackinac with the Army Corps review of a proposed reroute of the exact same pipeline in Wisconsin is the epitome of segmentation. The incongruity of separating the consideration of two projects that have the potential to lead to either the continuation of or termination of this pipeline is particularly striking again because scoping comments have raised the need to avoid segmentation of the review. This failure to comply with clear direction in NEPA alone should require either the determination that environmental threats are too great to issue the permits desired by Enbridge, or that the review must be dramatically modified to incorporate a substantive review of the full scope of environmental impacts from this action.

The failure to consider the full range of alternatives is also at odds with scoping for this project, in particular because the company’s own expert has explained in court proceedings that shutting down Line 5 would result in a de minimus increase in the cost of the products flowing through the pipeline and result in just a few months of delay before other pipelines owned by the company would be able to make up most or all of the loss of capacity. Objections to shutting down Line 5, which is an alternative that has not be adequately reviewed, focus in part of the claim that there would be an unacceptable impact on the propane availability in Michigan’s Upper Peninsula if the NGLs provided in the pipeline were discontinued. However, studies looking at the alternatives to provide propane and to provide for alternative sources of energy to replace the need for propane undermine that argument. Again, this information has been identified in scoping comments, and the Army Corps review failed to provide the required comprehensive review of potential alternatives.

The Army Corps has also intentionally left out consideration of the impacts on the environment and climate of the continued extraction and pumping of petroleum products through the Line 5 pipeline. These impacts start with the extraordinarily damaging impact of the extraction of these products, and continue to the end points where the burning of the products as is intended directly contributes increasingly to the greenhouse gas concentrations in the atmosphere which are endangering not just the local area around the proposed tunnel, but the entire planet. It is nonsensical to decline to consider the impact of the products the pipeline carries when the only purpose of the tunnel is to continue the transport of these very products. An honest review of alternatives must look not just at “no action” and all the alternatives identified which keep the oil and NGLs running through it, but at whether or not there is in fact a “need” for this current activity to continue. NEPA and federal water permitting were not written solely to determine the least impactful way for a permit applicant to damage the environment to achieve their purported goals. It was intended as well to ensure consideration of alternatives that could eliminate the harm from current activities, and there is no question that Enbridge’s current use of Line 5 to pump petroleum is a danger to the environment. In addition, the alternative of simply placing materials on top of the existing dual pipelines cannot be taken seriously because the pipeline is more than 20 years past it’s lifespan, has been bent and scarred multiple times and poses a current and ongoing threat to the Great Lakes that cannot be mitigated simply by attempting to cover it up. For 70 years Enbridge and its predecessor have been tinkering with the pipeline to continue its flow of products unimpeded, but these dual pipelines were never intended to be used this way, were not designed to be covered, and need to be shut down immediately to avoid catastrophic impacts in the world’s largest reserve of freshwater.

Thank you for the opportunity to submit comments. I am also signed onto comments submitted on behalf of Sierra Club and Oil and Water Don’t Mix, and these are my personal comments as a Michigander, and as a parent and grandparent concerned about the viability of their future.

As a leading agency for engineering, design, and development I understand as a citizen that the USACE is ran by intelligent hard working people. The USACE is there to serve the United States and its citizens and help protect and prevent us from harm. What I cannot understand is why an approval for a line that has leaked an average of 71 spills per year for the past 15 years, totaling 500,000 gallons of oil leaked into the worlds largest fresh water source would be considered USACE. Enbrige has already proven that their pipelines cause harm, why would we want to put the future of one of our greatest resources at the mercy of an entity that already has proven to cause harm.

Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted. Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well, you are more likely to influence the agency decision making process.

Because of the huge risks involved, this project demands a thorough a comprehensive risk assessment be performed. Rather than boring through solid, uniform bedrock, the proposed tunnel would have to bore through fractured, unconsolidated rocks with large open seams. For this reason, it is crucial that there be a very good understanding of the nature of the geologic materials underneath the Straits of Mackinac where the proposed tunnel would be built. Such an understanding of the nature of the materials where the tunnel would be built is critically important for the tunnel’s safe construction and operation. However it is clear that sampling of these geologic materials has been grossly inadequate. The frequency of sampling (i.e., samples per distance along the tunnel’s path) have been well below the industry standard, and a 1.5 mile section of the tunnel’s path has not been sampled at all. Moreover, a large fraction of the samples were not taken from the correct depth, making those samples of highly questionable utility. A tunnel pipeline that will transport hazardous materials has never before been built in the conditions that occur in the Straits of Mackinac (i.e., the length and depth of the tunnel with very poor rock conditions and very high hydrostatic pressure at tunnel depth). This necessitates that a very thorough risk assessment be performed before an extremely expensive and highly risky experiment be performed in the public waters of the Straits of Mackinac.

Oil needs to be a part of our past. An infrastructure project with a 50 year roi at this point is a sin against both nature and mankind.

NO approval until a more thorough review has been done. Reports show unstable rock/soils beneath the proposed tunnel. Violation of treaty rights. Concerns about potential explosion inside the proposed tunnel, and the difficulty of filling that tunnel with concrete. This pipeline is NOT needed and poses great threats to the Great Lakes, which are within the Public Trust. An oil spill would be catastrophic to the life within the lakes and all the industries that rely on our lakes (fishing, tourism, recreation, water supplies, and more. Do not rush this one through.