Name
Dan Kutschera
Organization/Affiliation
Entry Date
October 14, 2022 10:20 pm
Attachment
Comments
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 most productive part of
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 most productive part of
Name
Kim Waldman
Organization/Affiliation
Entry Date
October 14, 2022 10:18 pm
Attachment
Comments
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 most productive part of
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 most productive part of
Name
Marilyn Price
Organization/Affiliation
Entry Date
October 14, 2022 10:15 pm
Attachment
Comments
My request is that the Army Corps conduct a maximum scope EIS for the proposed tunnel expansion under the Straits of Mackinac and a full FEIS for the entire Line 5Pipeline!
Thank you for considering this request
Thank you for considering this request
Name
Melissa Evans
Organization/Affiliation
Entry Date
October 14, 2022 10:08 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am 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.
Name
Melissa Evans
Organization/Affiliation
Entry Date
October 14, 2022 10:07 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This review should be as thorough as possible in scope, including a detailed review of at least all of the following:
A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.
B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.
C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.
D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.
E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.
F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.
G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am 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.
Name
Debbie Winchester
Organization/Affiliation
Entry Date
October 14, 2022 10:05 pm
Attachment
Comments
Enbridge’s proposed Line 5 tunnel project will only wreak further havoc on the ecosystems and people which have already been harmed by the existing Line 5. As a concerned citizen, I urge the Army Corps of Engineers to think realistically about the future of our living planet when conducting this Environmental Impact Study on the Line 5 project. The extraction and burning of oil sands are some of the most environmentally damaging ways to produce energy—even more damaging than the industry has admitted, as found by a study done by John Liggio, et al. in 2019 (https://www.nature.com/articles/s41467-019-09714-9). Furthermore, Enbridge does not have a good track record with replacement projects — as recently as the construction of Line 3 last year, Enbridge claimed to be building a new pipeline in order to avoid operating a pipeline in dangerous condition, and in doing so caused an aquifer breach and subsequent groundwater leakage (https://www.mprnews.org/story/2022/08/06/line-3-aquifer-breach-is-leaking-more-groundwater). The project also damaged several wild rice lakes – which are sacred to the region’s Indigenous population – to the point where they can no longer be used by these communities. And this is just the tip of the iceberg – countless other untold sufferings have been caused by the recent construction of Line 3.
With this in mind, the impacts of Line 5 on local communities and on the global climate crisis will not be abstract — especially when we consider that the proposed project will cause further disruption to the Straits of Mackinac, even more than the existing pipeline already has. This will not only harm the land and water which Indigenous people of the region understand as sacred, but it will also risk contamination of the drinking water of more than 40 million people in the U.S. and Canada. Even if the proposed Line 5 project didn’t treat our water supply as something to be sacrificed for the sake of enriching those who profit from the oil industry, it would contribute significantly to greenhouse gas emissions, with Canada projected to blow right past its Paris Agreement promises (https://www.nationalobserver.com/2019/01/30/analysis/canadas-climate-gap-widens-yet-again). Most importantly of all, though, the proposed Line 5 tunnel has already been found to trespass on the treaty lands of the Bad River Band of the Lake Superior Chippewa (https://financialpost.com/commodities/energy/wisconsin-judge-rules-against-enbridge-dispute-line-5-pipeline). Those of us whose ancestors arrived on this land as colonial settlers have a moral obligation to do everything we can to return this land to the Lake Superior Chippewa, who have stewarded the region and its ecosystems for centuries.
It is certainly a tall order to provide energy to an increasingly overpopulated Canada and United States, and to maintain living wages for those employed by the existing energy sector. The solution, however, is not the status quo of building more tarsands pipelines. Rather, we must make a rapid transition away from dirty energy like tarsands. Shutting down Line 5 and stopping the Line 5 tunnel are critical steps in that direction.
With this in mind, the impacts of Line 5 on local communities and on the global climate crisis will not be abstract — especially when we consider that the proposed project will cause further disruption to the Straits of Mackinac, even more than the existing pipeline already has. This will not only harm the land and water which Indigenous people of the region understand as sacred, but it will also risk contamination of the drinking water of more than 40 million people in the U.S. and Canada. Even if the proposed Line 5 project didn’t treat our water supply as something to be sacrificed for the sake of enriching those who profit from the oil industry, it would contribute significantly to greenhouse gas emissions, with Canada projected to blow right past its Paris Agreement promises (https://www.nationalobserver.com/2019/01/30/analysis/canadas-climate-gap-widens-yet-again). Most importantly of all, though, the proposed Line 5 tunnel has already been found to trespass on the treaty lands of the Bad River Band of the Lake Superior Chippewa (https://financialpost.com/commodities/energy/wisconsin-judge-rules-against-enbridge-dispute-line-5-pipeline). Those of us whose ancestors arrived on this land as colonial settlers have a moral obligation to do everything we can to return this land to the Lake Superior Chippewa, who have stewarded the region and its ecosystems for centuries.
It is certainly a tall order to provide energy to an increasingly overpopulated Canada and United States, and to maintain living wages for those employed by the existing energy sector. The solution, however, is not the status quo of building more tarsands pipelines. Rather, we must make a rapid transition away from dirty energy like tarsands. Shutting down Line 5 and stopping the Line 5 tunnel are critical steps in that direction.
Name
Sandra Wheeler
Organization/Affiliation
Entry Date
October 14, 2022 10:04 pm
Attachment
Comments
Please fully assess threats due to the proposed location in the Straits of Mackinac.
The Great Lakes system has enormous intrinsic value. They are the largest source of fresh water on Earth, containing 5,500 cubic MILES of water. They are 95% of all fresh water in the US and provide drinking water for 48 million people.
The Straits of Mackinac are extremely vulnerable due in part to their singularly complex currents.
PLEASE pay close attention to the University of Michigan study by David Schwab and Eric Anderson published in Great Lakes Environmental Research in 2013. Schwab developed the first 3D, high resolution hydrodynamic model to accurately predict the oscillating currents’ effects could swirl oil into both lakes, concluding the Straits of Mackinac are “the worst possible place for an oil spill in the Great Lakes.”
The currents in Straits move 10 times more water than Niagara Falls, and do it quickly. Up to 80,000 cubic meter of water travels more than a yard every single second.
Astonishingly, these currents switch directions every few days. This wasn’t understood until the 1990’s, 4 decades after Line 5 opened in 1053.
Because of all this, a Line 5 rupture in the Straits could wreck over 700 miles of shoreline.
The Straits of Mackinac are also extremely vulnerable due to their complex underwater geology.
Brian O’Mara, a geological engineer with 30 years’ experience with high risk and Great Lakes tunnels, spent nearly 100 hours in 2020 reviewing Straits of Mackinac information and Enbridge’s geotechnical reports.
Enbridge’s design changes after its original proposal cut costs and increased risks, making their previous risk assessment invalid. Enbridge did no new risk assessment.
The original assessment assumed no toxic gases present. But methane was found in groundwater beneath the Straits. If it enters the tunnel, it will become a gas; any spark would trigger an explosion.
I’m a 1971 tunnel project under Lake Huron having similar geology, a methane explosion killed 22 men. According to The Detroit News Archives, the shockwave traveled at 4,000 mph with 15,000 pounds of force per square inch.
Enbridge has no plan to deal with this threat.
The original assessment assumed a tunnel through solid bedrock. Actually, there are poor quality limestone bedrock with fault zones under unconsolidated sediments—the most dangerous tunneling conditions.
Enbridge bored 20 samples across 19,000 feet, one every 950 feet. Industry standard is one every 50-200 feet. That’s 95 to 380 borings for 19,000 feet.
Enbridge’s ignorance of ground conditions could create sinkholes during boring. Unfortunately, part of the existing underwater pipeline is almost above the tunnel and still carries 23 million gallons of oil daily. A sinkhole affecting this aged pipeline could cause catastrophic damage.
The old risk assessment assumed a cement fill between the pipeline and tunnel to prevent leaks, explosions, possible collapse. The new design has no such cement protection.
According to O’Mara, “This single design change represents the greatest risk and would make a catastrophic disaster much more likely to occur.”
The earlier assessment was for a straight tunnel rising from south to north. The new design is a broad V-shaped tunnel, initially sloping downward. Any water flooding the entrance would trap workers below.
The boring machine could fail, even become stuck in place, necessitating disassembly and removal through the tunnel entrance. This could cause a delay of months, possibly even years.
Tunnel construction will shift flow of groundwater. Tunnels and shafts must be “de-watered” and kept dry, causing them to act as drains for water from all directions. They may pull lake water down into aquifers, contaminating well water with pollutants, damaging nearby wetlands with wastewater and construction waste.
O’Mara concludes, “What Enbridge has submitted to the State of Michigan doesn’t come close to properly designing and preparing for a tunnel underwater. Plain and simple.”
Mike Wilczynski is a former Senior Geologist for the former Michigan Department of Environmental Quality with over 40 years of environmental experience. Noting Enbridge’s plan to discharge 5 million gallons of wastewater into Lake Michigan every day during construction, he says, “What worries me most is a bentonite discharge into the Straits could be even worse than an oil discharge.”
The tunnel boring machine will inject bentonite slurry ahead of itself, a delicate process that needs comprehensive data on rock and soil above above the tunnel for proper balance to avoid collapse.
Accidental releases of bentonite slurry can occur during tunnel boring. Enbridge has no plan to prevent or control accidental slurry discharge.
Once mixed with water, bentonite will stick to everything, can stay suspended in water almost forever, and forms an impenetrable barrier.
This impenetrable barrier clogs gills of fish, suffocating them, destroying fisheries. Abundant reefs in the Straits form 70% of lower lakes fish breeding grounds according to environmental experts with the Sault Tribe of Chippewa who depend on these fisheries.
It also kills off organisms along the lake bottom and the shore, as well as destroying fresh drinking water.
Wilczynski concludes, “The existence of so many technical, risk management, and regulatory deficiencies at this [2020] stage of Enbridge’s proposal suggests the company has failed to properly plan, design, and ensure safe construction and operation of this proposed tunnel.”
Please note that my only personal “expertise” is the sum of Google searches done in an attempt to inform myself. Changes, even improvements, may have occurred since my sources reported then current conditions
However, each of these concerns seems significant enough to warrant more effective scrutiny by the Corps. Please bring your expertise to each of these threats and protect our vulnerable resources. Thank you.
The Great Lakes system has enormous intrinsic value. They are the largest source of fresh water on Earth, containing 5,500 cubic MILES of water. They are 95% of all fresh water in the US and provide drinking water for 48 million people.
The Straits of Mackinac are extremely vulnerable due in part to their singularly complex currents.
PLEASE pay close attention to the University of Michigan study by David Schwab and Eric Anderson published in Great Lakes Environmental Research in 2013. Schwab developed the first 3D, high resolution hydrodynamic model to accurately predict the oscillating currents’ effects could swirl oil into both lakes, concluding the Straits of Mackinac are “the worst possible place for an oil spill in the Great Lakes.”
The currents in Straits move 10 times more water than Niagara Falls, and do it quickly. Up to 80,000 cubic meter of water travels more than a yard every single second.
Astonishingly, these currents switch directions every few days. This wasn’t understood until the 1990’s, 4 decades after Line 5 opened in 1053.
Because of all this, a Line 5 rupture in the Straits could wreck over 700 miles of shoreline.
The Straits of Mackinac are also extremely vulnerable due to their complex underwater geology.
Brian O’Mara, a geological engineer with 30 years’ experience with high risk and Great Lakes tunnels, spent nearly 100 hours in 2020 reviewing Straits of Mackinac information and Enbridge’s geotechnical reports.
Enbridge’s design changes after its original proposal cut costs and increased risks, making their previous risk assessment invalid. Enbridge did no new risk assessment.
The original assessment assumed no toxic gases present. But methane was found in groundwater beneath the Straits. If it enters the tunnel, it will become a gas; any spark would trigger an explosion.
I’m a 1971 tunnel project under Lake Huron having similar geology, a methane explosion killed 22 men. According to The Detroit News Archives, the shockwave traveled at 4,000 mph with 15,000 pounds of force per square inch.
Enbridge has no plan to deal with this threat.
The original assessment assumed a tunnel through solid bedrock. Actually, there are poor quality limestone bedrock with fault zones under unconsolidated sediments—the most dangerous tunneling conditions.
Enbridge bored 20 samples across 19,000 feet, one every 950 feet. Industry standard is one every 50-200 feet. That’s 95 to 380 borings for 19,000 feet.
Enbridge’s ignorance of ground conditions could create sinkholes during boring. Unfortunately, part of the existing underwater pipeline is almost above the tunnel and still carries 23 million gallons of oil daily. A sinkhole affecting this aged pipeline could cause catastrophic damage.
The old risk assessment assumed a cement fill between the pipeline and tunnel to prevent leaks, explosions, possible collapse. The new design has no such cement protection.
According to O’Mara, “This single design change represents the greatest risk and would make a catastrophic disaster much more likely to occur.”
The earlier assessment was for a straight tunnel rising from south to north. The new design is a broad V-shaped tunnel, initially sloping downward. Any water flooding the entrance would trap workers below.
The boring machine could fail, even become stuck in place, necessitating disassembly and removal through the tunnel entrance. This could cause a delay of months, possibly even years.
Tunnel construction will shift flow of groundwater. Tunnels and shafts must be “de-watered” and kept dry, causing them to act as drains for water from all directions. They may pull lake water down into aquifers, contaminating well water with pollutants, damaging nearby wetlands with wastewater and construction waste.
O’Mara concludes, “What Enbridge has submitted to the State of Michigan doesn’t come close to properly designing and preparing for a tunnel underwater. Plain and simple.”
Mike Wilczynski is a former Senior Geologist for the former Michigan Department of Environmental Quality with over 40 years of environmental experience. Noting Enbridge’s plan to discharge 5 million gallons of wastewater into Lake Michigan every day during construction, he says, “What worries me most is a bentonite discharge into the Straits could be even worse than an oil discharge.”
The tunnel boring machine will inject bentonite slurry ahead of itself, a delicate process that needs comprehensive data on rock and soil above above the tunnel for proper balance to avoid collapse.
Accidental releases of bentonite slurry can occur during tunnel boring. Enbridge has no plan to prevent or control accidental slurry discharge.
Once mixed with water, bentonite will stick to everything, can stay suspended in water almost forever, and forms an impenetrable barrier.
This impenetrable barrier clogs gills of fish, suffocating them, destroying fisheries. Abundant reefs in the Straits form 70% of lower lakes fish breeding grounds according to environmental experts with the Sault Tribe of Chippewa who depend on these fisheries.
It also kills off organisms along the lake bottom and the shore, as well as destroying fresh drinking water.
Wilczynski concludes, “The existence of so many technical, risk management, and regulatory deficiencies at this [2020] stage of Enbridge’s proposal suggests the company has failed to properly plan, design, and ensure safe construction and operation of this proposed tunnel.”
Please note that my only personal “expertise” is the sum of Google searches done in an attempt to inform myself. Changes, even improvements, may have occurred since my sources reported then current conditions
However, each of these concerns seems significant enough to warrant more effective scrutiny by the Corps. Please bring your expertise to each of these threats and protect our vulnerable resources. Thank you.
Name
Craig Stephan
Organization/Affiliation
Citizens' Climate Lobby
Entry Date
October 14, 2022 9:57 pm
Attachment
Comments
Re: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I urge the U.S. Army Corps of Engineers to conduct a broad, thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act. It should consider all possible alternatives to a pipeline, and the risks involved both in constructing the pipeline and in operating it.
Thank you.
I urge the U.S. Army Corps of Engineers to conduct a broad, thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act. It should consider all possible alternatives to a pipeline, and the risks involved both in constructing the pipeline and in operating it.
Thank you.
Name
Anonymous Anonymous
Organization/Affiliation
Entry Date
October 14, 2022 9:54 pm
Attachment
Comments
As a US citizen living in the Great Lakes region, I oppose the construction and implementation of Line 5. Just one mistake, human or mechanical, could impact the drinking water of hundreds of thousands of people, let alone the food supply of them, or even a recreational venue. The Lakes are the lifeblood of the Upper Midwest and what happens in them flows all the way south. Enbridge's recent history of frackouts, drilling spills, and human and civil rights violations reveals that this technology and method is neither safe nor efficient. Adding to the list is the lengthy history of oil industry failure and corporate cover-up, activist and Indigenous resistance, high construction and maintenance and security costs, and need for eventual replacement of pipeline, this endeavor is not viable. To argue such is a moral and economic miscalculation.
Name
Jessica Berger
Organization/Affiliation
Entry Date
October 14, 2022 9:52 pm
Attachment
Comments
Ref: U.S. Army Corps of Engineers Project LRE-2010-00463-56-A19
I am urging the U.S. Army Corps of Engineers to conduct a thorough and complete review of the proposed tunnel project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This analysis must include the following:
1) A comprehensive analysis of alternatives to Line 5 or the replacement tunnel. As we transition away from fossil fuels, oil infrastructure in the Straits of Mackinac cannot be the only options evaluated. The review must consider more temporary alternatives that does not perpetuate fossil fuels like using Enbridge's existing capacity, utilizing trucks or railways.
2) Likewise, the review must consider the impact of green house emissions involved in Line 5 tunnel construction and pipeline operation or continued operation of Line 5 as status quo. It must consider that the emissions may go against the climate goals of the United States and Michigan.
3) The analysis should consider all environmental impacts of the entire span of the pipeline from Wisconsin to Canada. The tunnel perpetuates the lifespan of Line 5 and, therefore, all environmental impacts must be considered.
4) The analysis should consider the environmental impacts of a spill in the Straits of Mackinac or elsewhere along the pipeline's route. It should consider 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.
5) The USACE must meaningfully consult with Tribal Nations and prioritize their comments given the history of inadequate consultation and coercive treaties they have been subjected to. The analysis must consider how tunnel construction would harm an identified Indigenous cultural site located at the bottom of Straits of Mackinac.
6) The review must evaluate the risk of explosion during construction and operation. Experts have identified the significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Additionally, 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.
7) The review must thoroughly evaluate the bentonite drilling slurry proposed for use 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 as any spill would be a violation of Treaty rights. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.
Thank you.
I am urging the U.S. Army Corps of Engineers to conduct a thorough and complete review of the proposed tunnel project as part of its Environmental Impact Statement under the National Environmental Policy Act.
This analysis must include the following:
1) A comprehensive analysis of alternatives to Line 5 or the replacement tunnel. As we transition away from fossil fuels, oil infrastructure in the Straits of Mackinac cannot be the only options evaluated. The review must consider more temporary alternatives that does not perpetuate fossil fuels like using Enbridge's existing capacity, utilizing trucks or railways.
2) Likewise, the review must consider the impact of green house emissions involved in Line 5 tunnel construction and pipeline operation or continued operation of Line 5 as status quo. It must consider that the emissions may go against the climate goals of the United States and Michigan.
3) The analysis should consider all environmental impacts of the entire span of the pipeline from Wisconsin to Canada. The tunnel perpetuates the lifespan of Line 5 and, therefore, all environmental impacts must be considered.
4) The analysis should consider the environmental impacts of a spill in the Straits of Mackinac or elsewhere along the pipeline's route. It should consider 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.
5) The USACE must meaningfully consult with Tribal Nations and prioritize their comments given the history of inadequate consultation and coercive treaties they have been subjected to. The analysis must consider how tunnel construction would harm an identified Indigenous cultural site located at the bottom of Straits of Mackinac.
6) The review must evaluate the risk of explosion during construction and operation. Experts have identified the significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Additionally, 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.
7) The review must thoroughly evaluate the bentonite drilling slurry proposed for use 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 as any spill would be a violation of Treaty rights. 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.