Posted Scoping Comments

The Line 5 pipeline and tunnel are a threat to all the citizens who rely on the Great Lakes Water Authority (GLWA) for their drinking water. The GLWA pulls its water from Lake Huron. One spill or leak would poison Lake Huron and affect over 3.8 million people. We cannot afford another incident similar to Flint, Michigan, where incompetence and mismanagement poisoned many residents. Enbridge's history of spills and failure to follow the rule of law make it unworthy to continue to operate Line 5 and to construct a Line 5 tunnel. Stop this project before we have a catastrophic event.

Climate change is real. The atmospheric scientists are telling the truth. The planet and the people are in imminent danger from catastrophic changes to all Earth's systems. The only viable solution is to stop all new fossil fuel development.

Pipelines only do 2 things: transport dangerous chemicals, and leak. Please keep this are clean and refuse approval of the Enbridge Line 5 Tunnel. Thanks...Steve

Enbridge spilled 1.7 million gallons of oil in Grand Rapids, Minnesota, in 1991. It has been responsible for at least 804 oil spills from 1999 to 2010. It has spent more than $4 million into a fund for law enforcement agencies arresting people protesting their tar sands pipeline. They cracked down on protests with counterinsurgency experts like Troy Kirby who have quelled resistance to fossil fuel projects in places like Nigeria. Their pipelines transport tar sands and oil across Indigenous lands and violate Anishinaabe treaty rights. They threaten water safety. This is not a company I want risking the safety of 20 percent of the world's fresh water.
Line 5's inland sections have spilt more than 1 million gallons since 1968. It threatens the Great Lakes water, wildlife, and economy. Dr. Robert Richardson of Michigan State University issued a study of a conservative spill scenario for Line 5 and estimated $697.5 million in costs for natural resource damages and restoration and more than $5.6 billion in total economic impacts. This includes impacts on tourism, commercial fishing, municipal water systems, and coastal property values.
Line 5 is not critical infrastructure. London Economics International, LLC (LEI) under a contract with the National Wildlife Federation (NWF) with funding from the Charles Stewart Mott Foundation, released a study in 2018 stating that truck and rail can replace the supply of propane to the Upper Peninsula with an approximate increase in cost per gallon of only 5 cents for UP consumers.
We need to move away from fossil fuels, to prevent pollution, to prevent oil spills, to prevent running out of a limited resource, to prevent carbon emissions that will further warm our planet.

This permit should be denied because of Enbridge track record of terrible spills, including the 2010 spill in the Kalamazoo River basin. This pipeline was built here as a shortcut thru the states back to Canada. If Enbridge wants to continue with this pipeline, they should put it all in Canada. Or they could move their refineries to Canada area before the pipeline enters the states. They have options that are protective of the Great Lakes- but they just want the cheapest alternative to them. The cost of an oil spill from this pipeline is too great in terms of environmental damage. I highly recommend that this permit be denied, due to available alternatives and the risk of an environmental catastrophe. Thank you.

On Joe Biden’s first day in office, he signed multiple executive orders targeting the domestic fossil fuel industry. Those orders effectively killed the energy independence of the United States. The high fuel and energy prices Americans are now struggling to pay, are a result of this liberal democratic Administrations’ policies.
Electric vehicle manufacturers have made tremendous technology gains in the last decade. It will take continued technology improvements and break throughs to make electric cars more affordable and practical for more than the 1% of the population who currently own an EV. The same holds true for the alternative energy (wind/solar) industry.
America obviously will need fossil fuels to provide reliable electricity, gasoline, and diesel fuel to our country for many decades to come. Joe Biden should permanently reverse his executive orders and support the United States return to an energy independent country. Yeah, right. That won’t happen.
The proposed Line 5 tunnel project should be approved immediately and boring should commence. This is clearly a move to increase the safety of this pipeline and protect our fresh water. Shutting down this line would further exacerbate the high energy prices Americans are paying. The Army Corps of Engineers should not delay this approval.

Enbridge has a horrible track record of spills and should not be rewarded with a chance for more. I grew up spending part of every summer swimming in Lake Michigan. An oil spill in the Great Lakes would wreak havoc on the people living along the shoreline and the plants and animals that rely on the water in the lakes for their sustainability. And we all know how they do not take responsibility for the spills and take only desultory steps to clean up their messes. This pipeline would be bad for the environment and people...we need sustainable fuel not hazardous gas.

As homeowners on Lake Huron we are absolutely opposed to Line 5. There is no fail-safe way to pump oil through our waters, and definitely not through a very old pipeline. The damage of an oil leak in our Great Lakes would be irreparable and frankly incomprehensible.

Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19

I am writing to request 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:
Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for the transport of 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 the use of 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 train and truck. 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 lead to the decommissioning of the Line 5 pipeline in the near future. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
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 allow it to avoid a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
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.
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.
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.
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 U.S. and global climate policy.
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,

Alison Stankrauff
120 Seward
Apartment 408
Detroit, Michigan
48202

See this link 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 shorten 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 an detonation to occur in less than 20
minutes. The entire state of Michigan will be affected. 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!