Name
Paula Paula
Organization/Affiliation
Entry Date
September 4, 2022 5:21 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
We cannot risk contaminating the Great Lakes with potential oil spills from such a project. We need to focus on cleaner sources of energy and stop spending time and money expanding dangerous and inefficient fossil fuel projects.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
We cannot risk contaminating the Great Lakes with potential oil spills from such a project. We need to focus on cleaner sources of energy and stop spending time and money expanding dangerous and inefficient fossil fuel projects.
Thank you.
Name
Pamela MacPherson
Organization/Affiliation
Entry Date
September 4, 2022 3:55 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Maxine Zylberberg
Organization/Affiliation
Entry Date
September 4, 2022 12:06 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Arohi Nair
Organization/Affiliation
Entry Date
September 4, 2022 10:34 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Arthur Hirsch
Organization/Affiliation
Climate Reality Project- West Michigan Chapter
Entry Date
September 4, 2022 10:12 am
Attachment
Comments
Letter to Army Corps of
Engineers Ref: U.S. Army Corps of Engineers Project
LRE-2010-00463-56-A19 Subject: Line 5 Tunnel
EIS Comment Topic- Purpose and
Need The proposed Purpose and Need Statement is a critical part of the scoping process. The purpose and need provided on the Army Corps of Engineers (Corps) website is inadequate and provides very little detail what is being proposed. This purpose and need statement must be detailed, concise and for the alternatives to be fully evaluated beyond just the Tunnel
option.
Purpose Purpose and need statement: This statement must explain the reason the Corps is proposing the action and what the Corps expects to
achieve. The stated Purpose and Need in the Corps EIS website states the purpose of the project is to provide transportation of light crude oil, light synthetic crude oil, light sweet crude oil, and natural gas liquids between Enbridge’s existing North Straits Facility and Mackinaw Station, and to approximately maintain the existing capacity of the Line 5 pipeline while minimizing environmental
risks. According to the Council on Environmental Quality-Executive Office of the President; A Citizen’s Guide to NEPA (January 2021`) one key aspect of a draft EIS is the statement of the underlying purpose and need. Agencies must draft a “Purpose and Need” statement to describe what they are trying to achieve by proposing an action. The purpose and need statement is to explain to the public why an agency action is necessary, and serves as the basis for identifying the reasonable alternatives that meet the purpose and
need. NEPA CEQ Regulation 40 CFR 1502.13 – which states “The statement shall briefly specify the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action.” To date there are no proposed alternatives provided in Corps Tunnel 5 Purpose Statement; the Corps has failed in providing this critical
information. Army Corps Needs Analysis & Purpose Statement Guidance Document (July 24, 2014)- The purpose statement must establish and detail the benefit of the proposed action. The current Purpose Statement does not specify any benefits as per the guidance
document.
Need The Need (Problem) – The Need statement must provide data to support the problem statement (purpose). In addition, the need must describe the key problem or problems and the cause of those problems that are being addressed by the proposed project/action. The need provides the factual foundation for the statement of the project purpose (establishes the evidence that a problem exists). Empirical data in tables and graphs should be presented by the Corps to document a demonstrated need. This information is
missing. Army Corps Needs Analysis & Purpose Statement Guidance Document (July 24, 2014- states that the needs must be legitimate. It is the position of the State of Michigan and Native Nations/Tribes that this proposed action is not legal and legitimate
(https://earthjustice.org/cases/2021/line-5-pipeline). The applicant or the Corps has not established a realistic and legal Need for this proposed action; the “transportation of light crude oil, light synthetic crude oil, light sweet crude oil, and natural gas liquids between Enbridge’s existing North Straits Facility and Mackinaw Station” does not satisfy a current or future energy need by the State of Michigan nor the United States of American government; it only benefits the Enbridge Corporation in making more financial gain at the State of Michigan’s
risk. The stated Corps Need Statement mentions the need to minimizing environmental risks from the Tunnel; quite the contrary the Tunnel represents a unique set of environmental risks that cannot be eliminated or minimized such as green house gas emission and climate change from the use of fossil
fuels. Alternatives
Analysis The Army Corps failure to list any alternatives is concerning. It is not possible to comment on any purpose and need statement when this statement is flawed and there are not alternatives
listed. A comprehensive alternatives analysis needs to be performed by the Corps. Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting crude oil products currently exist without the Line 5 pipeline and tunnel. The alternatives analysis must include an alternative that considers using the existing capacity of the Enbridge system (like Lines 6A, 14, 61, 64, and 6B). If existing capacity is inadequate the alternatives should assess expanding capacity elsewhere in Canada or within the Enbridge System. The No Action needs to account for the fact that Enbridge would be operating the Line 5 Tunnel without a valid easement in Michigan and with Tribal Land in accordance with the Washington Treaty of
1836. The applicant has stated that there are no other alternatives than the Tunnel or trucks and train transport options which is incorrect and bias towards the tunnel construction (https://www.enbridge.com/projects-and-infrastructure/public-awareness/line-5-michigan/consider-the-alternative) . Again, this EIS scoping document fails to address alternatives such as existing under capacity lines that do not transport crude oil under the most sensitive part of the Great
Lakes. The Corps must consider the
following: Since the Corps has not posted realistic purpose and need statements and alternatives; it is impossible for the public to comment and react to them until the development of the Draft EIS which to much too late; the Corps must allow public review and comment to these critical EIS foundation
items. The Corps must properly use the alternatives analysis that selects the least environmentally damaging practicable alternative (LEDPA) using established CEQ criteria. This alternative needs to be established in the Draft EIS statement for public
comment. Avoidance and minimization measures must be applied equally across all alternatives for an objective comparison of
options The Corps must use criteria as to what constitutes a significant effect to human health and welfare and impacts to fish and wildlife
values. The alternatives analysis must consider the potential risk to the environment and the economy including tourism
jobs. The bottom line is that the Corps must develop an honest and factual purpose and need statement with all alternatives as the foundation of the EIS
Engineers Ref: U.S. Army Corps of Engineers Project
LRE-2010-00463-56-A19 Subject: Line 5 Tunnel
EIS Comment Topic- Purpose and
Need The proposed Purpose and Need Statement is a critical part of the scoping process. The purpose and need provided on the Army Corps of Engineers (Corps) website is inadequate and provides very little detail what is being proposed. This purpose and need statement must be detailed, concise and for the alternatives to be fully evaluated beyond just the Tunnel
option.
Purpose Purpose and need statement: This statement must explain the reason the Corps is proposing the action and what the Corps expects to
achieve. The stated Purpose and Need in the Corps EIS website states the purpose of the project is to provide transportation of light crude oil, light synthetic crude oil, light sweet crude oil, and natural gas liquids between Enbridge’s existing North Straits Facility and Mackinaw Station, and to approximately maintain the existing capacity of the Line 5 pipeline while minimizing environmental
risks. According to the Council on Environmental Quality-Executive Office of the President; A Citizen’s Guide to NEPA (January 2021`) one key aspect of a draft EIS is the statement of the underlying purpose and need. Agencies must draft a “Purpose and Need” statement to describe what they are trying to achieve by proposing an action. The purpose and need statement is to explain to the public why an agency action is necessary, and serves as the basis for identifying the reasonable alternatives that meet the purpose and
need. NEPA CEQ Regulation 40 CFR 1502.13 – which states “The statement shall briefly specify the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action.” To date there are no proposed alternatives provided in Corps Tunnel 5 Purpose Statement; the Corps has failed in providing this critical
information. Army Corps Needs Analysis & Purpose Statement Guidance Document (July 24, 2014)- The purpose statement must establish and detail the benefit of the proposed action. The current Purpose Statement does not specify any benefits as per the guidance
document.
Need The Need (Problem) – The Need statement must provide data to support the problem statement (purpose). In addition, the need must describe the key problem or problems and the cause of those problems that are being addressed by the proposed project/action. The need provides the factual foundation for the statement of the project purpose (establishes the evidence that a problem exists). Empirical data in tables and graphs should be presented by the Corps to document a demonstrated need. This information is
missing. Army Corps Needs Analysis & Purpose Statement Guidance Document (July 24, 2014- states that the needs must be legitimate. It is the position of the State of Michigan and Native Nations/Tribes that this proposed action is not legal and legitimate
(https://earthjustice.org/cases/2021/line-5-pipeline). The applicant or the Corps has not established a realistic and legal Need for this proposed action; the “transportation of light crude oil, light synthetic crude oil, light sweet crude oil, and natural gas liquids between Enbridge’s existing North Straits Facility and Mackinaw Station” does not satisfy a current or future energy need by the State of Michigan nor the United States of American government; it only benefits the Enbridge Corporation in making more financial gain at the State of Michigan’s
risk. The stated Corps Need Statement mentions the need to minimizing environmental risks from the Tunnel; quite the contrary the Tunnel represents a unique set of environmental risks that cannot be eliminated or minimized such as green house gas emission and climate change from the use of fossil
fuels. Alternatives
Analysis The Army Corps failure to list any alternatives is concerning. It is not possible to comment on any purpose and need statement when this statement is flawed and there are not alternatives
listed. A comprehensive alternatives analysis needs to be performed by the Corps. Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting crude oil products currently exist without the Line 5 pipeline and tunnel. The alternatives analysis must include an alternative that considers using the existing capacity of the Enbridge system (like Lines 6A, 14, 61, 64, and 6B). If existing capacity is inadequate the alternatives should assess expanding capacity elsewhere in Canada or within the Enbridge System. The No Action needs to account for the fact that Enbridge would be operating the Line 5 Tunnel without a valid easement in Michigan and with Tribal Land in accordance with the Washington Treaty of
1836. The applicant has stated that there are no other alternatives than the Tunnel or trucks and train transport options which is incorrect and bias towards the tunnel construction (https://www.enbridge.com/projects-and-infrastructure/public-awareness/line-5-michigan/consider-the-alternative) . Again, this EIS scoping document fails to address alternatives such as existing under capacity lines that do not transport crude oil under the most sensitive part of the Great
Lakes. The Corps must consider the
following: Since the Corps has not posted realistic purpose and need statements and alternatives; it is impossible for the public to comment and react to them until the development of the Draft EIS which to much too late; the Corps must allow public review and comment to these critical EIS foundation
items. The Corps must properly use the alternatives analysis that selects the least environmentally damaging practicable alternative (LEDPA) using established CEQ criteria. This alternative needs to be established in the Draft EIS statement for public
comment. Avoidance and minimization measures must be applied equally across all alternatives for an objective comparison of
options The Corps must use criteria as to what constitutes a significant effect to human health and welfare and impacts to fish and wildlife
values. The alternatives analysis must consider the potential risk to the environment and the economy including tourism
jobs. The bottom line is that the Corps must develop an honest and factual purpose and need statement with all alternatives as the foundation of the EIS
Name
Dan Robinson
Organization/Affiliation
Great Lakes Spirituality Project
Entry Date
September 4, 2022 9:48 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
We should always come down on the side of caution. If a spill happens, the Lakes will be decimated for a very long time.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
We should always come down on the side of caution. If a spill happens, the Lakes will be decimated for a very long time.
Thank you.
Name
A Martin
Organization/Affiliation
Entry Date
September 4, 2022 9:35 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Steven Dusing
Organization/Affiliation
Entry Date
September 4, 2022 7:35 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be thorough, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
E) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
F) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be thorough, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
E) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
F) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Sara Syswerda
Organization/Affiliation
Entry Date
September 4, 2022 6:00 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Name
Lisa George
Organization/Affiliation
Entry Date
September 4, 2022 5:58 am
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
Greetings from Northport on the Leelanau peninsula. I live here. The water is everything to us and, as we are seeing across the US right now, fresh water will continue to be precious. We must save and protect our Great Lakes. Period.
I am asking that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
These are points of review that I have seen suggested and support fully. Please, won’t you proceed as if you hold our future in the balance?
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
Greetings from Northport on the Leelanau peninsula. I live here. The water is everything to us and, as we are seeing across the US right now, fresh water will continue to be precious. We must save and protect our Great Lakes. Period.
I am asking that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
These are points of review that I have seen suggested and support fully. Please, won’t you proceed as if you hold our future in the balance?
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.