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 to build a new Enbridge Line 5 pipeline under the Straits of Mackinaw as part of its Environmental Impact Statement under the National Environmental Policy Act. Milwaukee Riverkeeper is a non-profit organization based in Milwaukee, Wisconsin, but we remain highly concerned over the impacts on water quality, wildlife, quality of life, and our $10 billion water-based tourism economy from a potential rupturing or explosion of that pipeline. Oil would likely spread over a sizable portion of Lakes Michigan and Huron, and could be carried to our area by a strong north or northeast wind. In addition, the Great Lakes provide drinking water for 40 million Americans and Canadians, and all of us that drink that water should have a say in this project.

The environmental 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.

Also, Enbridge has a history of oil spills, including the Kalamazoo River spill, which was the most expensive cleanup in US history. The company has had recent spills and violations of their permit in MN and WI, as well as Michigan, and is currently operating the existing Line 5 without the easements/state approval to do so in the State of Michigan. As a private company, they are not accountable to voters or citizens, only their shareholders. Please protect us from this project, which poses a serious threat to our drinking watersupplyandthreatensourfishandaquaticlifequalityoflifeandwater-basedtourismeconomy.Thankyou

Please see the comments on behalf of Tip of the Mitt Watershed Council and the Michigan Environmental Council.

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.

Please decomission Line 5 immediately. This pipeline is a ticking timebomb under the most pristine freshwater in the world. The Great Lakes must be valued (economically, socially) above any natural gas and propane pipeline at this stage in the climate crisis. Here are some facts I urge you to take into consideration:
Line 5 is a harmful pipeline that carries 87 million litres of oil and gas per day through the Great Lakes, including through the Straits of Mackinac – a six km wide connection between Lakes Michigan and Huron. If it ruptures, it’s projected to contaminate up to 1200 km of Great Lakes shoreline in the U.S. and Canada. This project would potentially add 27 million metric tons of carbon pollution annually.
USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation regarding recently discovered ancient Anishnaabeg cultural artifacts at the Straits of Mackinac.
At least 29 spills have happened and 4.5 million liters of oil have already been spilled along the entirety of the Line 5 route.
This is unacceptable. Please decommission Line 5 immediately.

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.

Attached is a written statement developed by a group of students at Michigan State University for the purpose of expressing our collective concerns with the continued operation of Line 5 and any further infrastructure in connection with the pipeline. Our position is founded on a wide array of academic fields of study with multiple concerns considered and discussed within the written statement prepared.

Please consider the concerns listed below as to why I OBJECT TO THE PIPELINE:

Cumulative impacts – 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 expansion through 180+ waterways that flow into Mashkiiziibii, the Bad River watershed, in 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. Built in 1953 with an engineered lifespan of 50 years, the decaying Line 5 has spilled over a million gallons, with soil contamination found as recently as last month



Tribal sovereignty – the EIS must recognize that any action short of decommissioning Line 5 directly undermines Indigenous rights, violates long-standing Treaty agreements with sovereign Indigenous nations that are designated by US Constitution Article VI as the supreme law of the land, threatens the majority of the country’s fresh surface water, and perpetuates the climate crisis. Continuing to run fossil fuels under the Straits of Mackinac places massive, unnecessary risk on the Great Lakes and Michigan’s twelve federally recognized Tribal Nations – which together make up the Three Fires Confederacy of the Ojibwe, Odawa, and Potawatomi – against their will, in effect furthering cultural genocide. Damage to land and water destroys food and cultural lifeways that are core to Tribal members’ identity and survival.



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 located at the bottom of the Straits of Mackinac, near the proposed project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations. Significant care must be taken to preventthis.

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

Quite simply the existing pipeline is 70 years old. It is very doubtful that it can operate another 30 years without a major malfunction resulting in an environmental disaster that would be devastating to the communities and ecosystem not just in the immediate area but the Great Lakes writ large. Or damage from shipping or Enbridge's failure to build the pipeline according to the required and agreed upon specifications.

The proposed new pipeline will be built by the same company (Enbridge) that did not follow the design specs on the first pipeline. The same company that has experienced more that 30 pipeline ruptures and spills in the state of Michigan. It is no wonder (certainly not altruism) that they want to give the line to Michigan when complete. Michigan will then alone bear the cost of the ensuing environment disaster that will undoubtedly, sooner or later, occur. Is there anything more valuable in the world, certainly not oil, than clean, drinkable fresh water? It is insane to risk this most valuable resource for the sake of profits for a foreign company. No pipeline carrying any substance that can cause as much permanent damage as this one can should be built near the Great Lakes shoreline. For these and the following reasons I request the the U.S. Army Corps of Engineers deny permitting for this project. 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 theLine3expansionprojectshouldcallitsmethodsintoquestion.AbentoniteslurryspillintotheStraitsofMackinacmustbeavoidedatallcosts.Thankyou.