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.

Thank you.

I am in support of the new Line 5 Tunnel. Line 5 has been a critical link to having sufficient fuel supplies in the UP. History has shown the current Line 5 to be very safe until sabotage started to take place and even then there has been little to no environmental impact.
The new tunnel is a very secure plan to continue to balance environmental protection and adequate fuel supply. And the cost is being paid by private dollars thus no cost to taxpayers.
I am in favor of the Line 5 tunnel.

Enbridge does not have the best safety record. Our Great Lakes are an integral part of our economy and the ecosystems in Michigan. I do not trust Enbridge to maintain this pipeline and ensure no contamination. We should be moving away from fossil fuels so it should not be needed in the future. I encourage you to deny Enbridge the rights to put a pipeline through our great lakes.

While admittedly a citizen who has no engineering education, it came to mind that a compromise in the Line 5 tug-of-war might reside in building the pipeline above the water, attached directly to the Mackinaw bridge, perhaps 10-20 feet above traffic flow.. There would be plenty of eyeballs crossing the bridge to discover any leaks, or relatively simple safety features would/could eliminate any possibility for potential leakages of energy product to fall/enter the Mackinaw Straits below..

Please use the link below to a Commentary I authored in the April 8,2022 issue of Michigan Advance. The title is "Why the Enbridge Line 5 tunnel is a pipe bomb at the Straits"

https://michiganadvance.com/2022/04/08/column-why-the-enbridge-line-5-tunnel-is-a-pipe-bomb-at-the-straits/

What follows is a shortened version of that paper:

Twenty percent of the time the pipeline in the tunnel will transport a mixture of highly flammable propane and butane. Should a leak in the pipeline occur in the 99-year life of the tunnel, propane and butane would be released into a "Confined Space" – the tunnel. A very hazardous situation. Calculations have shown that a tiny 1/8 inch diameter leak could cause a detonation equivalent to 345 pounds of TNT to occur in less than 20 minutes.

Without justification, the assumption has been made that since the pipeline is in a tunnel there is nothing to worry about. In other words the probability of a leak in the pipeline, within the tunnel, is so low a disaster will never happen. We don't need to worry about the consequences.

It's bad logic, and therein lies the fatal flaw.

It's the sort of reasoning that led to the nuclear reactor disasters at Chernobyl and Fukushima.

A leak of propane or butane inside the tunnel can occur. When that happens, there will be a detonation. Our pristine Straits will be destroyed. Even worse there will be fatalities.

The entire state of Michigan will be effected. Pollution of the Great Lakes, violation of tribal agreements, loss of tourism jobs, commercial and sport fishing ruined, beaches ruined, Mackinac Island “shut down” — the list goes on and on. Michigan, along with Wisconsin and Ontario, will pay the price. We cannot afford to guess and hope not to have a disaster for nearly a century.

The tunnel must not be built!

Line 5 currently provides jobs and resources beyond Enbridge. When this tunnel is built the State will continue to be a safe transportation route for energy and the many jobs tied directly or indirectly to these energy sources we use everyday. The history of line 5 through the Great Lakes is one of quality work that continues to provide safe transportation to this day. By building this tunnel the operation only becomes more secure and the opportunity to connect the LP and UP expands greatly. Let's be level headed, understand our water is important, and move forward in a responsible manner to keep the Lakes clean, the energy flowing and the jobs in Michigan.

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.

Line 5 only provides a small fraction of the propane used in Michigan, and the U.P. Energy Task Force has found solutions for the U.P. that will keep costs low while maintaining access. Line 5 was built to be a shortcut through Michigan to transport crude oil from Canadian tar sands
to Canadian refineries. It is not a propane pipeline and there are numerous alternative sources of propane for the U.P. This isn’t about heating homes. This is about a Canadian oil company trying to protect its profits at the risk of our Great Lakes. Enbridge Energy's own experts testified in court that a Line 5 shut down would only impact fuel prices less than 1 cent.

A LINE 5 RUPTURE WOULD DEVESTATE OUR ECONOMY AND COST HUNDREDS OF THOUSANDSOF JOBS
More than 214,000 Michigan jobs are supported by tourism alone, which are at risk if Line 5 ruptures. Enbridge only employs 116 people in Michigan, including contractors. An independent 2017 study by Dynamic Risk found decommissioning and removing Line 5 would create 2,188 jobs.

A Line 5 oil spill would damage 700 miles of Great Lakes shoreline - This includes destroying habitat & coastlines in the Beaver Island Archipelago!

Source: https://michiganlcv.org/wp-content/uploads/2022/08/Line-5-Two-Pager_8.18.22.pdf

Building the tunnel is the absolute best approach to keeping the pipeline operational and safe.
Any comments about a potential leak causing harm are extremely irrational. The tunnel is below the water bed, if the pipe were to leak it would have to fill the entire tunnel with fluid and then build up enough pressure to overcome the external pressures outside of the tunnel to escape. If in the future the pipeline is decommissioned and the tunnel is empty, it can be repurposed for other utilities. This is a great project that should have started years ago, I fully support the building of the tunnel ASAP.

I am writing to question the need for the Line 5 Tunnel. As a former resident of Chicago who drank Lake Michigan water every day, I am still concerned about preserving the purity of the Great Lakes. While burying the existing pipes under the lake instead of keeping them on the lake bottom itself seems to be a better solution, I wonder what other options exist that do not involve possible contamination of the lake itself. I am part of a local organization that is concerned about the pollution of Lake Memphremagog with leachate from the only landfill left in Vermont. We have found that the state agency responsible for administering environmental protections has been unable to provide an answer to us about removal of these pollutants once they enter the lake. Prevention of ongoing pollution seems a better bet than attempts at remediation, which are likely to be costly and ineffective.