Supplemental Draft EIS Comments

This is a bait and switch by Enbridge and the Army Crops of Engineers. Enbridge cannot safely perform HDD Drilling in the Straits of Mackinac, and their track record of frack-outs in their line 3 expansion project demonstrates this. This project still forces Michigan taxpayers to carry all the risk for a foreign corporation. The tunnel would transfer catastrophic financial risk to Michigan taxpayers while Enbridge profits. With insurance covering less than 4% of potential damages and Michigan slated to own the infrastructure, this is a bad deal for our state.

Michigan families should not be left holding the bill for Enbridge's profits.

There has to be a better way. Don't do this.

I am writing to oppose the use of HDD in the Straits of Makinac. Here are some of the reasons:

- This is a suspicious change by Enbridge and the Army Corps of Engineers, after focusing on the tunnel for years.
- The Executive Summary says "The HDD Installation Alternative was evaluated in USACE’s May 2025 Draft EIS but considered infeasible, based on a 2018 Enbridge report, and therefore eliminated from detailed analysis in the EIS. USACE subsequently received information indicating that the HDD Installation Alternative is now feasible due to advances in technology since the 2018 report. I find it hard to believe that just 7 months after the EIS, this is a total turnaround. Again, it is suspicious.
- The May EIS concluded that this alternative was not technically feasible due to the length of the replacement pipeline, length of drill required, and the hard characteristics of the subsurface rock. Things like that don't change with a few years of technology advances. Certainly not the subsurface rock!
Has a HDD of the length (3.5 miles), under a major waterbody (not a small stream or riverbed) ever been contemplated or successfully accomplished? Why would we be ok with such an important waterbody, the Straits of Mackinac, being the testing ground for such an attempt?
- The assembly areas require "Tree clearing (approximately 31.9 acres South and 9.6 acres North) would result in long-term impacts due to the slow regeneration rate of trees." Darn right! I have spent time in those cedar groves overlooking the Mackinac bridge and Straits. "The degree of impact to the viewscape would depend on individual location and perception." My perception is that this is not acceptable! "Overall vegetation clearing (including logging) could be up to 51.4 acres South and 47.8 acres North." This in sensitive areas (Headlands International Dark Sky Park, French Farm Lake Flooding State Wildlife Management Area, McGulpin Lighthouse, Mackinaw Area Historic Society Heritage Village, Colonial Michilimackinac Historic State Park, and Hiawatha National Forest) we don't want changed from forest to meadow (per the SEIS). Nor do we believe these changes would end when construction is complete! That is a false statement at best.
- Enbridge cannot safely perform HDD drilling in the Straits of Mackinac. Their track record of frac-outs in their Line 3 expansion project demonstrates this.
- Regarding groundwater: Approximately 15.8 acres total ground disturbance would occur within expected construction footprints, which could result in detrimental impacts to surface waters adjacent to construction footprints due to erosion and sedimentation. We are not convinced that adherence to the SESC plan and required permits (including NPDES) would mitigate this.
- During construction, there would also be potential for detrimental impacts associated with unintended release of contaminants, such as equipment fuel. Again, evidence shows Enbridge doesn't repair the messes they leave. Citizen monitors in MN show that groundwater heating, contamination and other problems continue. Enbridge pays a pittance of a fine and doesn't permanently correct the issues. See work of Adookawad Amikwaad. Same with wetlands - Enbridge has been fined $72 million for breaking water use laws in MN, but we still trust them? Line 5 has leaked over 30 times, that we know of. Just last year in Jefferson County, WI, which they didn't report for over a month, saying is was 2 gallons when it was more like 70,000 galloons! Why do we keep doing the same thing over and over with Enbridge expecting a different result? Their pipelines cause problems that they don't fix.
- We brush off concerns about surface water, wetlands, groundwater, aesthetics, terrestrial and aquatic habitat as "temporary", but that just isn't true when you are significantly changing the landscape. Concerns about protected species like long-eared and tricolored bats are "mitigated" by tree cutting outside pup season. And massasauga rattlesnake - they will coordinate with USFWS and MDNR. So what does that mean to those species?
- Archeological resources - "potential impacts/impact avoidance, minimization, and mitigation efforts minimized". How about not disturbing them in the first place. Regarding Treaty Rights they don't even pretend to mitigate - just "To Be Determined in the Record of Decision"
- Enbridge minimizes even serious geological concerns: "the potential for development of karst conditions can lead to challenges with excavation stability. Vibrations given off by the HDD during drilling activities have the potential to cause shifts in the geology around the alignment, which could contribute to borehole instability and the possibility of inadvertent returns of drilling fluid." But all this will be mitigated later. Again, look at Enbridge's track record. We can't trust them with our precious resources for CN oil company profits.
Of great concern is the risk of blowing up the area. "If pockets of hazardous gas (e.g., methane) exist along the HDD alignment, the potential to encounter those pockets is greater for the HDD Installation" because technology including sensors on the drilling head are not available for HDD. That is an unacceptable risk. This alone should disqualify HDD drilling in the Straits.
- Overall - everything that will or could go wrong or have a negative impact is minimized as either temporary, or to be mitigated. But many impacts are definitely not temporary, and mitigation isn't the point. We don't want it impacted in the first place to continue fossil fuel infrastructure for another 100 years in the Great Lakes. The Great Lakes belong to the people - not a Canadian oil company focused on continued planet warming fossil fuel use so they can preserve their profits, while Great Lakes States take all the risk.

This project still forces Michigan taxpayers to carry all the risk for a foreign corporation. A recent report shows:
- Michigan will own the tunnel and inherit massive liability
- Enbridge's insurance covers less than 4% of potential damages
- Worst-case costs could exceed $45 billion
- The "watchdog" agency was designed to partner with Enbridge, not protect taxpayers
- No comprehensive review of these types of risks has been completed

This line does nothing to mitigate the disaster posed by the previous line, line 5. Building a new line beneath an active line, a risky line at that, does nothing but continue to perpetuate the risk of oil contaminating the Great lakes IRREPERABLY. This is the most blatant bait and switch tactic, and it is beyond lazy. We the citizens are telling you no, you cannot build a new oil pipeline beneath the current pipeline. That poses an intense risk to Michigan waters & ecology. This would not be an oil spill that could be cleaned. Our fresh water in Michigan is the largest fresh water source on earth. It is abysmal you would even consider doing this for the sake of profit. Lastly, Canada legally is not owed access to this land, water or oil. This is unacceptable. You may NOT proceed. We are not asking, we are telling you. Shame on you.

Please allow further research and investigation as well as public comment before approving this permit.
The number of dangers and risks that the communities of Michigan would have to take on is egregious.
I'm greatly concerned about the ground water quality and the fact that monitoring would only occur for 2 years after construction. This is highly inadequate when we can only estimate how long it would take for contamination to spread from the site and where. Even so, if a problem is found years later, how would it be addressed? I can only be reminded of other such communities that suffered years later after drinking contaminated water.
The risk during construction and after construction puts many local people at risk who get their drinking water from ground water wells.
After construction, should there be a pipeline rupture or fracture, how will it be contained? How will the integrity of the pipeline be tested and confirmed without causing contamination to any aquifer that is being bore through? How will it be tested for compliance after it is in operation? How will a fracture be corrected should one occur during construction after the line has been put in place beneath the lakebed? Has any research been done for repair construction should it need to occur and the impact that it would have? How would this impact the surface water as well as the ground water? The geology suggests that it wouldn't be feasible to contain and repair such a fracture.
Further study needs to be done on who could potentially be affected by contamination to their drinking water and those people have a right to be informed.
I also have concerns how this would affect local fish populations. This is within a highly critical pinch point between the two lakes. Has the effect of vibrational and sound disturbance been studied and documented for the areas of spawning close to the construction? How will the construction affect any existing ecological restoration occurring in the area and how will that be remedied?

Please consider this permit affects more than just water and land. It will disrupt many communities way of life and has the potential for permanent irreversible harm.

This proposal should be blocked as the company involved has a history of unsafe practices and the project risks causing long-lasting cataclysmic damage to the surrounding environments. This company has already engaged in egregious violations of basic safety regulations and caused major widespread ecological damage, including in 2010 when they were responsible for the Kalamazoo River oil spill, which making it the 2nd biggest inland oil spill in United States history. On top of the unquantifiable cost if this harm to our wildlife, this grievous mistake was also a huge waste of resources in terms off labor and capital, being that it took over 10 years and more than $1 billion to clean up the spill. The Line 5 pipeline is already problematic, in that its already been dented, shifted by anchors, and stripped of its protective coatings over years of weathering, and it cuts through extremely sensitive wild areas that are supposed to belong to the Indigenous community whose reservation it resides on. Even aside from this blatant disregard to Indigenous sovereignty, according to University of Michigan News, “researchers have concluded that it is in the worst possible place in the Great Lakes for any pipeline to transit.” If the Line 5 pipe proposed here were to rupture in the Great Lakes, it would cause irreversible contamination to one of our largest sources of freshwater/drinking water at a time where Michigan residents are already acutely aware of how precarious the availability of clean water can be, given the fact that places like Flint and certain areas of Detroit still don’t have access to clean drinking water from their taps. Of course, a crisis like that would disproportionately affect those of lower socioeconomic standing such as the Black and Indigenous civilian communities of low-income status in nearby neighborhoods that can’t afford to import water from sources away from the Great Lakes. Additionally, a rupture of Line 5 in the Great Lakes would no doubt kill vast amounts of wildlife, drastically reducing biodiversity and throwing the whole ecosystem out of balance. Not only would this project be extremely dangerous, but it is completely unnecessary given that Line 5 is not the only possible source of propane for those in the Upper Peninsula. Upper Peninsula Energy Task Force and Gov. Gretchen Whitmer have already provided viable alternative solutions to the reliance on propane in those areas including investment in rail infrastructure and storage, providing heating assistance for families in need to protect consumers from price gouging, and making continual progress towards the overall transition to renewable energy and electrification. In conclusion, this proposal completely disregards Indigenous sovereignty, environmental regulations, and basic common sense and simply is not worth the risk.

I strenuously oppose putting a new pipeline under the straits of Mackinac, particularly by Enbridge. That company has demonstrated its willingness to take shortcuts that jeopardize the environment and have had catastrophic spills in the Kalamazoo River. There are untold risks to the environment should a rupture occur.

Absolutely remove the pipeline to Canadian grounds and out of the largest fresh water system in the world! Our water is not up for negotiation! Oil and water don't mix

I oppose the new alternative. The tunnel should be completely decommissioned.

The pipelines in the Straits of Mackinac cross one of the most ecologically sensitive areas in the world. The Great Lakes are home to 21 percent of the world's fresh surface water. The pristine Straits area supports bountiful fisheries, provides drinking water to thousands of people, and anchors a thriving tourism industry with historic and beautiful Mackinac Island right in the center. This area is the definition of Pure Michigan.

Additionally, its expired easement means the pipeline is now trespassing across the Bad River Band of Lake Superior Chippewa’s reservation.

Do not destroy our precious resource by running pipelines through this land and water.