As a longtime Michigan resident (55 yrs) I strongly oppose this pipeline, which places our Great Lakes at great risk of contamination, and their ecosystems of being disrupted. An oil spill will severely damage our beach tourism industry, our fishing and recreational industries.
Based on the discussion below, I conclude that the ACE has not done its due diligence. Instead, it: A) failed to consider the findings and actions flowing therefrom of the Michigan Propane Security Plan – Ensuring Resilience Without Line 5; B) failed to adequately assess the safety of the project and its impact on the aquatic ecosystem and other significant environmental resources and services (40 C.F.R. §230.10(a)); and C) may have relied on applicant’s biased and incomplete information.
There is, in fact, no reasonable alternative to the current Line 5 pipelines under the Straits, and the ACE should immediately deny the permit application. Additionally, the applicant should be required to shut down and decommission the existing pipelines currently posing an untenable risk to human, aquatic and other ecological systems health of the region, and to the more than 1.3 million jobs directly tied to the Great Lakes.
Issues with the draft EIS:
A. USACE did not examine “the full scope of possible alternatives and components.” There are two additional alternatives available:
1) The use of existing pipeline – Line 6B/78 – consideration of which was directed in January by then Acting Assistant Dir. of the Army.
2) The shut down and decommissioning of Line 5, given the development of alternative propane supplies under the Michigan Propane Security Plan. The construction of the tunnel, if it is ever completed, will take more than 5 years, allowing these alternative supplies to be fully developed and in place at shut down.
B. USACE failed to adequately assess the design of the project and its impact. The Corps should require an independent analysis.
1) Feasibility: No tunnel in similar conditions has ever been successfully completed because tunneling beneath open water is not just dangerous, it is hugely challenging.
i. No extensive or adequate evaluation of the true risks and consequences related to the Line 5 tunnel project has been completed. This includes from primary agencies and entities beyond USACE, including:
a) MI Department of Environment Great Lakes, and Energy (EGLE)
b) MI Public Service Commission (MPSC)
c) Mackinac Straits Corridor Authority (MSCA)
d) U.S. Pipeline and Hazardous Materials Safety Administration (PHSMA)
e) Labor unions
f) Local, state and federal elected officials
g) Enbridge
2) Enbridge failed to address critical criteria or consider the worst-case scenario:
i. The tunnel design fails to meet MI 2017 Alternatives Assessment study criteria, including, among others:
a) Being completely installed within competent bedrock.
b) Being completely backfilled / sealed with grout/cement, rather than simply between the pre-cast concrete lining and the tunnel itself.
ii. The tunnel design fails to include a fire suppression system. As such, the structure will be vulnerable to damage/catastrophic failure from explosion/fire, posing a huge risk to workers and the environment.
iii. Construction may create sinkholes under the existing pipelines and trigger a catastrophic full breach failure directly into the Straits.
iv. Because the pressure differential between the rock/sediment overburden and the tunnel will be > 250 psi, in a catastrophic failure, the Line 5 product will immediately migrate into the Straits.
v. According to experts, during construction, excavation slurry will discharge 5 million gallons of wastewater per day into Lake Michigan. Enbridge does not disclose the additives it will use and has no plans to extract the bentonite clay component that will coat everything in its path.
C. The ACE may have relied on applicant’s biased and incomplete information:
1) It is unclear whether USACE adequately evaluated Enbridge’s information on environmental impacts, including decommissioning sub-alternatives. Taking such information from the permit application at face value is failing to perform its official duties, thus nullifying its conclusion.
In closing, the USACE did not do its due diligence. It must re-start this process and address these absences and inadequacies. This is most especially vital, given the enormous human and ecosystem health impacts the project is anticipated to produce. A corporation’s interest must not take precedence over what it best for the Great Lakes’ incipient and adjacent ecosystems, and all other impacted parties.
I am writing to express my concerns and dissent for the Enbridge Line 5 Tunnel Project. As a Michigan resident, I care deeply about my home state, and as an engineering student, I care deeply about the energy solutions we build to further the most critical goal of our time: to reduce our dependence on fossil fuels. This project should not be fast-tracked in response to a manufactured energy emergency, and a comprehensive risk assessment of the entire impact of the tunnel should be undertaken, including the impact of an oil spill in the Straits of Mackinac.
I take issue with several points raised in Table ES-1: High Level Summary of Impacts:
Section: Recreation — Water Based. The EIS states that the Applicant’s Preferred Alternative would have “no need for future inspections or maintenance of the Dual Pipelines.” This is counterintuitive to the NTSB’s finding in the 2010 Kalamazoo River oil spill that Enbridge’s pipeline integrity management program “did not account for errors associated with in-line inspections and the interaction of multiple defects on a pipeline.” The EIS must take into account Enbridge’s history of inadequate inspections and maintenance.
Sections: Groundwater and Surface Water. The EIS states that the Applicant’s Preferred Alternative has “potential for direct, detrimental impacts to groundwater quality, due to a potential release of drilling fluids during HDD/TBM use, a potential release of contaminants associated with onshore material storage… approximately 20000 gallons of drilling fluid… would be released.” These “potential release” statements are vague, and must be quantified, labeled, and assessed for risk to the safety of water sources.
Section: Construction Risk. The EIS states that there is “potential to encounter unstable geology during drilling” and “potential to encounter hazardous gases that could pose a risk of explosion or asphyxiation.” This is a gross simplification of the technical difficulties underlying tunnel construction. Some of these include: poor quality rock that increases the risk of subsidence; hazard of explosion due to oil and natural gas fumes; and insufficient research on rock quality.
We cannot continue to be dependent on fossil fuels, for the future of our waters and our planet. Enbridge has demonstrated the hazardous effects of its oil pipelines in 2010, spilling 1.1 million gallons in the Kalamazoo River. The 40 million people that depend on drinking water from the Great Lakes cannot accept the Straits of Mackinac being used as a testing ground for an unstudied oil pipeline with a rushed and faulty analysis. In addition, USACE cannot fast-track this process that will destroy a sacred place and disregard Tribal sovereignty without full Tribal consultation. I urge USACE to pause all approvals until a full environmental review is completed.
Thank you for your time.
Margaret Strand
It’s clear to me that a pipeline through the Straits will have huge negative effects on water quality and on the fisheries and recreation industries on which many Michiganders depend, not to mention our family’s own enjoyment of the Great Lakes. A spill would be devastating. I am well aware of this since my husband is a hydrogeologist who has worked on many spills including the Gulf spill and the Kalamazoo spill. Although after many years these are supposedly “cleaned up”, there continue to be repercussions to the local people.
We are currently in a climate emergency, exacerbated by the burning of fossil fuels. It makes no sense to me to lock in more use of fossil fuels by building Line 5. We have two baby grandchildren. What kind of future would this subject them to?
Please pause all approvals until a full EIS is complete that addresses all these concerns. Thank you.
The tunnel trespasses on native lands, but also posses a risk to the Great Lakes. Spills could/will pose major risks to our water, wildlife, and to the environment. I am deeply, morally against the line 5 tunnels.
For example, one portion of the EIS stood out being as especially unclear: 3.1.3 Indigenous Knowledge/Traditional Ecological Knowledge, IK and TEK. It was explained as already being incorporated into the EIS and that only some topics would be considered for inclusion. But what topics ? What was the Indigenous knowledge offered? Where can I find their actual statements. What was learned by the USACE? How can I find those results?
I am left feeling very unsatisfied. Please extend the comment period to include opportunities to ask questions and get clarification,
Bernadette Knaeble