Tell the Army Corps: Reject the Line 5 expansion and shut the pipeline down!

The Line 5 oil pipeline threatens the Great Lakes, ignores treaty rights of tribal nations, and perpetuates a reliance on climate-busting fossil fuels.

The U.S. Army Corps of Engineers (USACE) is asking for public comment on the proposed Enbridge Great Lakes Tunnel plan as it prepares an Environmental Impact Statement (EIS). This comment period is an opportunity to demand that Line 5 receives the thorough review it requires and, ultimately, gets shut down.

Submit a public comment and help shut down Line 5 before this neglected pipeline causes irreversible damage to the Great Lakes and the communities and fragile ecosystems that depend on them.

Photo:Aubrey Antles

The Line 5 oil pipeline threatens the Great Lakes, ignores treaty rights of tribal nations, and perpetuates a reliance on climate-busting fossil fuels.

Submit a public comment and help shut down Line 5 before this neglected pipeline causes irreversible damage to the Great Lakes and the communities and fragile ecosystems that depend on them.

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Your Message

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

To US Army Corps of Engineers:

Message Body

I am writing to request that the U.S. Army Corps of Engineers conduct a thorough and complete review of the proposed project as part of its draft Environmental Impact Statement (DEIS) 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:

1. Comprehensive alternatives analysis: Independent studies have revealed that Line 5 is an unnecessary piece of infrastructure; other options exist that could be implemented in short order to transport the products currently transported on Line 5. Therefore, a DEIS with only two alternatives, a review of the existing Line 5 pipeline and a tunnel with a new pipeline,would accordingly be inadequate. The alternatives analysis should therefore include an alternative that fully considers the use of excess capacity in existing pipelines other than Line 5 to transport the products that the proposed project is designed to accommodate. If a thorough alternatives analysis projects that existing capacity is inadequate, then a fourth alternative should assess expanding capacity elsewhere within the existing pipeline system. In addition, 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 lead to the decommissioning of the Line 5 pipeline in the near future. Thus, the “no action” alternative cannot assume that Line 5 will continue to function indefinitely.

2. Consideration of all cumulative impacts: Regardless of its scope, the DEIS 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. Improperly segmenting permitting requests for multiple related projects on the same pipeline would preclude a thorough review of all cumulative impacts and potential environmental and climate damages of an unnecessary pipeline through a critical and fragile ecosystem.

3. 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 not rely on the inadequate geotechnical review and should instead 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.

4. 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 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.

5. 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. PHMSA also 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, indicating explosivity risk during construction as well, something that must be considered in the DEIS.

6. Climate impacts: 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 should fully review the potential climate impacts of this proposal to ensure that it adheres to the goals of U.S. and global climate policy.

7. Drilling slurry: The applicant proposes to use a bentonite drilling slurry to bore beneath the Straits of Mackinac, treaty-protected fishing grounds for local tribes and the most productive part of the Great Lakes tribal fishery. Bentonite drilling slurry is potentially toxic if released into the environment, where it expands and can coat the gills of fish, resulting in large fish kills. The DEIS must assess the potential impacts of a spill of bentonite as well as all other potential constituents of the drilling slurry that might be used in this project. Enbridge’s track record of recent frac-outs on the Line 3 expansion project also requires comprehensive review of its drilling methods. A bentonite slurry spill into the Straits of Mackinac must be avoided at all costs.

Thank you,

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