Posted Scoping Comments

Please reject Line 5 and all the infrastructure being asked to go with it. As a Minnesotan who has gone through this over the past decade with Line 3, we have many examples to share about how Enbridge handles itself in the United States. First, remember this is a Canadian company. They don't care about the welfare of Americans, our Native relatives or otherwise. This takes me to the second point, which focuses on our Native relatives. They've divided our Native communities, destroyed their land, destroyed their Manoomin beds by stealing the Niibi/Water from their lakes/rivers, poisoned their Nibi/Water. And they will do this to you for Line 5 too.

I'm sure you already know about the 28 frack-outs that took place in 2021 in a very short period of time, with one of them taking place while I was at one of the locations. Enbridge wasn't going to say anything, but since we were all gathered there, a few people noticed all the sludge that was collecting in Mississippi next to where it happened. In fact, Enbridge covered up many of their breaches, and our so-called Pollution Control Agency let them get away with it. They were able to continue their work, even as they continued to cover-up damage, and cover-up the fact they were doing work without permits.

Our governor wrote them a blank check and gave them millions of gallons of Nibi/Water to waste on a dying industry. You shouldn't be investing in oil, which some car makers aren't even making gas-powered cars anymore. You should be investing in green technologies that reflect the present and the future: solar, electric vehicles, wind, hemp, growing food locally...Please do NOT let this happen to the people of Michigan. Someone needs to look out for Americans and our safety. That's the role of the Army Corps of Engineers. Learn from all the harm that's been done here in Minnesota to our human relatives, nonhuman relatives, Nibi, land and air. With all the breaches they created in Minnesota and in 2021 alone that they sought to cover up (and never received a consequence for), imagine what the consequences will be for Michiganders if they're drilling under the Straits.

Please do not allow our Michigan neighbors to be harmed in the same way Minnesotans are now at risk. Minnesotans and everyone downstream on Mississippi River. We know there will be a major spill one day, as there biggest spills have already been here in Minnesota. Prevent this from happening in Michigan by just saying no to this tunnel and Line 5 altogether!

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 risks of contaminating our pure Michigan waters from damage to the current pipeline or from accidents & disturbances created from a tunnel are too great & I agree that Enbridge projects should be banished from the Great Lakes of Michigan & most especially from any lands & waters that are suppose to be under treaty protections of Indigenous Tribal Councils.

At a meeting I attended in St. Ignace a few years ago it was my understanding that Enbridge carried only one million dollars of insurance in the event that an oil spill occurred. That is a ridiculously low amount of insurance & I mention it because it speaks to the intent & character of this corporation. I do not know if the insurance coverage was ever increased but the idea that it was ever so low leads me to believe that this corporation does not care much about the well being of our environment or of the people who love our waters & wish to protect our waters. Many people at that meeting expressed concern for whether it would even be possible to clean up a spill that happened underneath the ice. I have not seen that Enbridge has ever satisfactorily addressed these concerns.

I feel, too, that there is a basic disrespect for Indigenous populations. I have spoken with people who have been to recent Enbridge meetings & who have worn traditional clothing or carried traditional regalia & were told by Enbridge representatives that these things were not allowed, & at other times that “costumes” would not be allowed. Those wearing traditional dress are not playing with costumes, & to suggest so is at the very least a form of ignorance & at the worst a form of discrimination against Indigenous people.

Enbridge is a large Canadian Corporation, & some have argued that it is even a monopoly. As I looked online I noticed that it is even big enough to sell shares on the New York Stock
Exchange. That suggests money & power, & a certain obligation to make money for the people who invest in their stocks. Why doesn’t Enbridge do it’s investors & our environment a favor & become leaders in clean energy! They are large enough to respond to the changing times instead of clinging to ways that have caused environmental harm (Kalamazoo, etc.) & that might again cause harm.

We don’t need any more bullies on the scene forcing their ways on our environment & our citizens. We need corporate leaders who have the integrity, character & vision to dream into reality a world where the beautiful resources we are gifted with are appreciated & protected. That includes everything & everyone. You can still make your money, Enbridge. Just do it in ways that help our world & our people to really thrive. Just be decent.

Dear Army Corps of Engineers:

I am not a scientist nor an engineer nor an expert in any field having to do with oil or water or pipelines. I am a citizen of Michigan, a resident of the Leelanau Peninsula which is surrounded by Lake Michigan. I have serious concerns about the continued existence of Line 5 in the Straits of Mackinac, and the proposal to build a tunnel.

Based on the age of the pipeline, the accidents which have already occurred, and the very unsatisfactory responses Enbridge has had to these and their other pipelines (Kalamazoo River) it would be irresponsible to expand their privileges as a foreign company using our highly sensitive land and water areas to supply their country with oil. (Most of the oil is transported back to Canada.)

Why are citizens and experts here being asked to prove technically how and why conditions, lakebed, designs, and environment are not suited for this project? Why are officials bending backward to accommodate the request of an irresponsible, life-threatening (accidents have impacted lives) foreign company’s business venture who has already caused permanent harm in Michigan (Kalamazoo River)?

I know that each day the oil flows Enbridge profits greatly. At the same time, each day the oil flows we risk the horror of an oil spill in our beautiful and precious Great Lakes. These waters serve all of us in countless ways. The tunnel will take many years to complete, the pipeline is aging and already way beyond its estimated age of durability, leaving us open and vulnerable to a disaster on the Great Lakes. Boring into the bedrock of the bottomlands under the Straits by a company whose track record is littered with unreported issues, late reported issues, slow and unsatisfactory responses to problems, and a limited monetary responsibility in the event of disaster is plain and simply - a very bad idea!

I urge you not only to conduct an extremely thorough review and broad analysis of the proposed tunnel, but to consider your part in preventing a very bad idea from becoming a very bad and disastrous reality for the water, the wildlife, the businesses and the people of our entire state of Michigan.

I urge you to deny permission to further develop Line 5 in the Straits of Mackinac.

Thank you for your time.

Denise Sica
Northport, MI

Ref: USACE Project LRE-2010-00463-56-A19
Thank you for accepting public input regarding the scope of this crucial EIS. In solidarity with the affected Indigenous women who have been meeting with you – the Indigenous Women’s Treaty Alliance facilitated by the Women’s Earth and Climate Action Network (WECAN) – regarding the disastrous ongoing and potential impacts of Enbridge Line 5 on their territories, I request USACE conduct a complete review of the proposed project as part of its EIS under the National Environmental Policy Act.


This review should be as thorough as possible in scope, including at minimum:

* Comprehensive alternatives analysis – independent studies have shown Line 5 is unnecessary (1); other options for transporting its products exist and could be implemented in short order. Therefore, framing the review with the only two options being the existing Line 5 versus the proposed tunnel can produce only an incomplete analysis. To avoid this inadequacy, the alternatives analysis should include an option that considers using the existing capacity elsewhere within Enbridge’s pipeline system. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s 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 MI without a valid easement (2), in violation of the expressed will of Michigan’s twelve federally recognized Tribal Nations who are stewards of this land and water (3), and in spite of banishment by the Bay Mills Indian Community (4); and in Wisconsin, Enbridge continues operating Line 5 years after eviction by the Bad River Band of Lake Superior Chippewa (5). Ongoing lawsuits from the State of MI and the Bad River Band could result in the decommissioning of this pipeline, significant for the “no action” alternative. In fact, in May 2021, Enbridge filed a depreciation study with the Federal Energy Regulatory Commission in which it proposed an accelerated depreciation schedule, estimating its Lakehead System had a remaining economic life of 19 years (6) – until 2040 – making Line 5 and the proposed oil tunnel an obvious candidate for decommissioning in 2022.



* 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 (7).



* 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 prevent this.



* Inadequacy of geotechnical studies – Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly one-tenth of the industry recommended research for a tunnel of this scope. The inadequacy of geotechnical study has not been considered by either the review of Michigan Department of Environment, Great Lakes, and Energy (EGLE) or Michigan Public Service Commission (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.



* 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 liquid gas 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 – In MPSC testimony (8), experts presented climate impact analyses of this proposal and indicated the 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 it adheres to the goals of the U.S. and global climate policy.



* Drilling slurry – The applicant proposes to use a bentonite drilling slurry in a massive 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

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.

In addition, Enbridge's history of operation and maintenance of their pipelines is horrendous. There have been 33 failures in Line 5 since 1968 and the oil spill into the Kalamazoo river from another of their pipelines was a huge environmental disaster that took years to clean up. They have never produced proof that they have insurance to cover any spills in the Straits of Mackinaw should one occur. They cannot be trusted and the risks are too great.

If a pipeline originating in northern Canada, conveniently passing through a short cut in Michigan, and terminating in southern Canada for the benefit and convenience of a foreign corporation were proposed today, the public outrage would be overwhelming and such a project would never be built!

The tunnel is a pipeline dream for an energy source [fossil fuels] that is on the way out. I am opposed to the tunnel project and support the total shut down of Line 5.

Thank you.
Kathleen Hibbard

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



Keep in mind, please, that fossil fuels are an anachronism, which means a future short life span and a long-term problem when things go wrong. The State of Michigan has already suffered enough from Enbridge's lack of foresight.

There is no question in my mind that Enbridge's Great Lakes Tunnel plan will ultimately result in being the most devastating disaster that occurs to fresh water on the globe. How can we even be considering such a thing?

Enbridge, like our former president, Trump, is a liar -- money first and no consideration for harm to humanity and the environment and ALL its inhabitants. It has been shown by scientists that Enbridge (END-bridge) is willing to sacrifice the well-being of the Earth -- not just the local Great Lakes. SHAME, SHAME on those who willingly choose to destroy the Earth and its inhabitants.

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.ind our

Thank you for accepting public input regarding the scope of this crucial EIS. In solidarity with the affected Indigenous women who have been meeting with you – the Indigenous Women’s Treaty Alliance facilitated by the Women’s Earth and Climate Action Network (WECAN) – regarding the disastrous ongoing and potential impacts of Enbridge Line 5 on their territories, I request USACE conduct a complete review of the proposed project as part of its EIS under the National Environmental Policy Act.

This review should be as thorough as possible in scope, including at minimum:

* Comprehensive alternatives analysis – independent studies have shown Line 5 is unnecessary (1); other options for transporting its products exist and could be implemented in short order. Therefore, framing the review with the only two options being the existing Line 5 versus the proposed tunnel can produce only an incomplete analysis. To avoid this inadequacy, the alternatives analysis should include an option that considers using the existing capacity elsewhere within Enbridge’s pipeline system. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s 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 MI without a valid easement (2), in violation of the expressed will of Michigan’s twelve federally recognized Tribal Nations who are stewards of this land and water (3), and in spite of banishment by the Bay Mills Indian Community (4); and in Wisconsin, Enbridge continues operating Line 5 years after eviction by the Bad River Band of Lake Superior Chippewa (5). Ongoing lawsuits from the State of MI and the Bad River Band could result in the decommissioning of this pipeline, significant for the “no action” alternative. In fact, in May 2021, Enbridge filed a depreciation study with the Federal Energy Regulatory Commission in which it proposed an accelerated depreciation schedule, estimating its Lakehead System had a remaining economic life of 19 years (6) – until 2040 – making Line 5 and the proposed oil tunnel an obvious candidate for decommissioning in 2022.

* 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 (7).

* 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 prevent this.

* Inadequacy of geotechnical studies – Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly one-tenth of the industry recommended research for a tunnel of this scope. The inadequacy of geotechnical study has not been considered by either the review of Michigan Department of Environment, Great Lakes, and Energy (EGLE) or Michigan Public Service Commission (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.

* 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 liquid gas 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 explosive risk during construction as well.

* Climate impacts – In MPSC testimony (8), experts presented climate impact analyses of this proposal and indicated the 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 it adheres to the goals of the U.S. and global climate policy.

* Drilling slurry – The applicant proposes to use a bentonite drilling slurry in the drilling under the Straits of Mackinac. Bentonite drilling slurry is a 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 both Treaty-protected and the most productive fishing grounds for local Tribes.