Posted Scoping 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 don't have unlimited great lake water resources. let is important to protect this beautiful and productive waterway system. Its essential.
Please.

Thank you

Eileen

We CANNOT risk any contamination of the Great Lakes, especially with climate change and its threat to turn our water into the next hot commodity!

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.

The health of the Great Lakes is critical to the health of Michigan. Line 5 should be taken out of service and this tunnel should not be allowed.

I urge you to deny the permit to construct the tunnel.

NO TUNNEL
Placing a tunnel across the Straits is a step backward in terms of creating a sustainable, stable climate. We need to do everything possible to move away from fossil fuel and forward to a clean environment.
The Straits is no place for such a tunnel.

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.

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.

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.

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.

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.