The Draft Environmental Impact Statement (EIS) reveals a number of serious concerns that cannot be ignored. First and foremost, the withdrawal of Michigan Tribal Nations from Cooperating Agency status in March 2025 highlights fundamental flaws in the consultation process. These sovereign nations were not meaningfully included, and their withdrawal reflects a deep mistrust in the integrity of this process. This is unacceptable, especially given that the proposed tunnel passes through culturally and historically significant areas.
It is also deeply concerning that key federal agencies, including the Advisory Council on Historic Preservation (ACHP), Bureau of Indian Affairs, Pipeline and Hazardous Materials Safety Administration (PHMSA), and U.S. Fish and Wildlife Service (USFWS), declined to serve as Cooperating Agencies. Their absence suggests serious reservations about the project’s scope, safety, and environmental implications. A limited review by just the U.S. Coast Guard, USEPA Region 5, and the Michigan State Historic Preservation Office is not sufficient for a project of this magnitude.
The compressed review timeline only adds to the concern. Environmental assessments of this scale typically require years to properly assess risks. Cutting corners to expedite the permitting process, as noted by Beth Wallace of the National Wildlife Federation, is “reckless.” These procedures exist to protect our communities, environment, and cultural resources, not to speed up profits for a foreign oil company.
Additionally, the project would result in the permanent loss of approximately 19 acres of wetlands, vegetation, and bat-roosting trees, habitats critical to regional biodiversity. The tunnel construction also threatens to disturb archaeological sites and groundwater, potentially damaging irreplaceable cultural resources and altering delicate subsurface hydrology. These risks are not minor and must not be dismissed in the interest of speed or convenience.
Finally, this project is centered around extending the life of Line 5, a pipeline with a dangerous track record. Enbridge’s history in Michigan includes the catastrophic 2010 Kalamazoo River oil spill, and Line 5 has already been struck multiple times by ship anchors while lying exposed in the Straits of Mackinac. Housing it in a tunnel does not eliminate risk, it only changes it.
We must prioritize long-term environmental protection, Indigenous rights, and public safety over short-term economic gain. I urge decision-makers to reject this tunnel proposal and instead invest in sustainable, forward-looking energy solutions.
Ann Arbor, Michigan
June 18, 2025
I am Dr Larry Junck, MD, a physician in Michigan. I am writing on behalf of myself but also for Michigan Clinicians for Climate Action, an organization of health care providers and others concerned about health of the people of Michigan. I recommenda AGAINST approval of the pipeline.
The most important reasons NOT to build this tunnel are because of its health concerns, including the air pollution caused by the burning of petroleum, including that carried by this tunnel, in our vehicles, businesses, and homes, and the health harms associated with climate change caused by the fossil fuels carried by this tunnel.
Regarding air pollution, few people are aware of the huge effects of air pollution on everyone’s health. The worst components of the air pollution are the particulates, of which petroleum is the main source. The harms continue even when we can’t see the pollution and when the air pollution is within the limits as defined by the EPA. The leading problems caused by this pollution are heart disease and stroke, followed by chronic lung disease, lung infections, and lung cancer. It also contributes to problems in our children including low birth weight, asthma, autism, and others. These problems cause about 100,000 deaths in the US and 8 million worldwide each year.
Regarding the effects of climate change, there is no doubt that the fossil fuels, including those carried by this tunnel, are leading to warming of our planet. Climate change threatens our health in many ways. Direct heat effects can be a large problem, especially for agricultural and industrial workers, but also for young children and the elderly. Climate change makes conditions more favorable for infections includng Lyme disease, which is increasing substantially in Michigan and other states, also, malaria, dengue fever, and others. It contributes to deaths and other health problems from extreme health events, such as Hurricane Helene which hit North Carolina and other states last fall, causing many deaths and $60B in damages
Others have commented about the jobs that will be created by construction, building a pipeline that will supply dirty energy that harms our health. A better argument is that construction of more sustainable sources of energy will create a larger number of jobs that will supply us with clean energy.
I point out that most of the speakers favoring this tunnel represent workers interested in short term jobs. They have a financial conflict of interest. There is nothing wrong with having a conflict of interest, but it must be acknowledged. As a physician concerned about the health of the people of Michigan and elsewhere, I have no such conflict of interest.
This tunnel is intended to continue our dependence on petroleum and other fossil fuels from the 19th and 20th century. A better idea that we as a society should be moving to the clean energy sources of the 21st century.
If this application is to move forward, I recommend that health analysis be performed that assesses the harms to health caused by the dirty petroleum that will flow through this tunnel.
Enbridge Energy filed papers with the Federal Energy Regulatory Commission claiming they plan to depreciate all their pipelines within 20 years. This allows Enbridge to charge a cost-of-service toll to investors which increases the fuel price within the pipeline. The tunnel, at the earliest if all goes perfectly, would be completed in 2028 – 29, meaning the 99-year-old tunnel would be used for about 11 years, leaving the State of MI to decommission the tunnel and pipelines. Will Enbridge invest 1- 2 billion dollars in a tunnel they plan to utilize for a short time? The pipeline tunnel would be a stranded asset costing the State of Michigan taxpayers millions to maintain.
Brian O’Mara, Director, Industrial and Power Sector Remediation Solutions at Lone Wolf Resources, LLC, an environmental engineer with decades of tunnel and pipeline construction and maintenance experience, said the poor quality of the bedrock (beneath the Mackinac Straits) will make completing the tunnel challenging. He suggested that it is possible an explosion or fire would put workers at risk and many thousands of gallons of natural-gas liquids could be released into the Great Lakes. It should be noted that in 1971 22 men were killed and nine injured in an explosion inside a Lake Huron water intake tunnel owned by the Detroit Water and Sewerage Department. A spark ignited an unseen cloud of methane gas, creating an explosion that caused a massive shock wave to travel the length of the tunnel. O’Mara suggested that the risks of explosion and fire could be alleviated by filling the tunnel with concrete around the pipeline. This was the original tunnel design proposed to the Snyder administration, but Enbridge has since altered the design.
Michigan Public Service Commission (MPSC) Staff Witness Travis Warner summarized the Alternatives Analysis (Line 5 Tunnel project) by “testifying that “the risks associated with the potential for a release of Line 5 products to enter the waters of the Great Lakes from a Straits tunnel crossing based on the current design, as proposed, is negligible, and un-quantifiably low.” (Warner Testimony at 22:12-16).
Richard B. Kuprewicz, president of Accufacts, Inc. pipeline regulatory advisor, incident investigator, and expert witness on matters related to gas and liquid pipeline siting, design, operation, maintenance, risk analysis, and management testified on behalf of Bay Mills Indian Community that the tunnel does not negate the risks of an explosion and release of oil and gas into the Straits. Mr. Kuprewicz is an engineer with substantial experience with oil and gas pipelines. He testified in opposition to the Mackinac Straits Corridor Authority (paid for by MI taxpayers but working directly with Enbridge). Enbridge attempted to have Mr. Kuprewicz testimony withheld from the court in the Nessel (on behalf of the State of MI) vs. Enbridge suit but luckily this was denied.
The case, Nessel vs. Enbridge Energy has been mired in litigation. Hopefully, the Michigan courts will follow the law and allow Michigan to protect the Great Lakes and Michigan citizens.
With gratitude for the work you do,
Sue Holcombe