Posted Scoping Comments

please see our comments attached, thank you

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

I am requesting that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.

This review should be as thorough as possible in scope, including a detailed review of at least all of the following:

A) Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is not a necessary piece of infrastructure and that other options for transporting the products currently transported on Line 5 exist and could be implemented in short order. A review of the existing Line 5 pipeline vs. the tunnel as the only two options would accordingly be inadequate. To avoid this inadequacy, the alternatives analysis should include an alternative that considers using the existing capacity in Enbridge’s pipelines to transport the petroleum products that the proposed project is designed to accommodate. If existing capacity is inadequate, the alternative should assess expanding capacity elsewhere within Enbridge’s existing pipeline system, as well as alternative forms of transport such as trains and trucks. The “no action” alternative should account for the fact that Enbridge is operating Line 5 in Michigan without a valid easement, and in Wisconsin, it continues to operate years after being evicted by the Bad River Band of Lake Superior Chippewa. Ongoing lawsuits from the State of Michigan and the Bad River Band of Lake Superior Chippewa could soon lead to the decommissioning of the Line 5 pipeline. Thus, in USACE’s alternatives analysis, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.

B) Cumulative impacts: Regardless of its scope, the EIS must consider all indirect and cumulative impacts and avoid segmentation of other pending proposals to modify Line 5, including, but not limited to, the proposed reroute of Line 5 through northern Wisconsin. Allowing Enbridge to improperly segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary pipeline expansion through a critical and fragile ecosystem.

C) Inadequacy of geotechnical studies: Initial geotechnical studies performed on the site for the Line 5 tunnel are inadequate, comprising roughly 1/10th of the industry recommended research for a tunnel of this scope. The inadequacy of the geotechnical review has not been considered by either the review of Michigan EGLE or MPSC. USACE must thoroughly review the complex geological and hydrogeological conditions that exist in the Straits of Mackinac and could preclude the feasibility of safely building a tunnel in this location.

D) Potential archaeological and cultural site: USACE must meaningfully consult with Tribal Nations, the State Historic Preservation Officer, and the Advisory Council on Historic Preservation in the NHPA Section 106 process regarding potential adverse effects to the potential 10,000-year-old Indigenous cultural site that has been located at the bottom of the Straits of Mackinac, near the proposed tunnel project. Tunnel construction could destroy this potential world heritage site and important cultural resource for local Tribal nations, and all care must be taken to ensure that this will not happen.

E) Explosion risk during construction and operation: Over the course of MPSC’s review of this proposal, expert testimony indicated a significant risk of explosion due to operating an oil and NGL pipeline within the confines of a subterranean tunnel with an open annulus design. Further, PHMSA expressed concerns to MPSC about the operations and maintenance of this pipeline within the confined space of a tunnel. USACE must fully evaluate this risk. Further, in the limited geotechnical analysis that was completed, dissolved methane in groundwater above reportable levels was detected. This leads to an explosivity risk during construction as well.

F) Climate impacts: Also, in MPSC testimony, experts presented climate impact analyses of this proposal and indicated that this project would potentially add 27 million metric tons of carbon pollution annually. USACE must fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of the U.S. and global climate policy.

G) Drilling slurry: The applicant proposes to use a bentonite drilling slurry in the Tunnel Boring Machine to drill through the Straits of Mackinac. Bentonite drilling slurry is a potential hazardous waste. Bentonite, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Given that the Straits of Mackinac are Treaty-protected fishing grounds for local Tribes and are, in fact, the most productive part of the Great Lakes Tribal fishery, the use of bentonite drilling slurry must be evaluated. Enbridge’s track record of recent frac-outs on the Line 3 expansion project should call its methods into question. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.

Thank you.

Please accept the attached comments from the Oil and Water Don't Mix Coalition, et al.

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

I request that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its Environmental Impact Statement under the National Environmental Policy Act.

This review should be as thorough as possible in scope, including a detailed review of at least all of the following:

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) I am especially concerned about shortfalls of geotechnical studies an urge you to require another series of geotechnical studies that provide complete analytical data on this complex underwater site. 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.nhe

I have been involved in advocating for the restoration and protection of the Great Lakes for 10+ years when I first learned about toxic algal blooms in Lake Erie. I find it incomprehensible that we are not more protective of our freshwater resources, our sources of drinking water and a rare watershed not found anywhere else in the world. Enbridge Line 5 is a clear and evident threat which we have the ability to eliminate and must do considering the value and the potential horror of failing to do so. Billions of dollars have been spent in restoration work and great benefit has been derived (for every $1.00 spent in restoration we have seen $3.00 in return on investment; $4.00. in some places in the Great Lakes region). This investment also must be protected. As we move towards a clean energy environment, we must not put greater investment and value into old technology and dirty energy investments. It makes no sense and our future selves will wonder why we made such a decision. Please think forward to what is needed and what is coming as you make this decision. 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

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.

The comments above seem to be comprehensive and state more eloquently than I could the many reasons why this tunnel is dangerous, unnecessary, and an active threat to our children's future. My only addition would be to note the mind-boggling number of accidents Enbridge has caused and the outright lies they have employed to cover their track record and delude the citizens of Michigan into believing they should continue to allow this corporation to take a money-saving shortcut through our most precious heritage: our waters.

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

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.