December 10, 2020

Kiana Courtney

Proposed Line 5 pipeline tunnel puts the Great Lakes at risk, Army Corps must consider climate impacts

The proposed Enbridge tunnel under the Straits of Mackinac would carry 23 million gallons of light crude oil and liquid natural gas daily, posing inherent environmental risks to our Great Lakes. The Corps must take into consideration the environmental risks related to the whole pipeline and potential leaks and spills.

The Straits of Mackinac is a critical juncture, connecting Michigan’s North and South peninsulas with Lakes Michigan and Huron. These Great Lakes provide drinking water to millions and support the region’s economy in fishing, recreation, and trade. The proposed Enbridge tunnel under the Straits of Mackinac would carry 23 million gallons of light crude oil and liquid natural gas daily, posing inherent environmental risks to these precious water resources.

At this week’s permit application hearing before the Army Corps of Engineers, ELPC spoke out about the risks of both tunnel and pipeline, and asked the Corps to do the following:

First, the Corps must conduct an Environmental Impact Statement (EIS) under the National Environmental Protection Act (NEPA). This EIS should consider the environmental effects of the pipeline as a whole because the Corps is required to consider the cumulative impacts of the project on our environment. While the Corps has indicated that it is only focused on the tunnel segment of Line 5 and cannot regulate the risk of spills or leaks, the Corps should still take into consideration the environmental risks related to the whole pipeline and potential leaks and spills. This project allows for the continued operation of Line 5 for 99 years. That is almost a century of cumulative impacts.

Continuing the transport of light crude oil and natural gas for 99 years is not in the public interest.

Second, the Corps should consider the implications of increasing greenhouse gases emissions from and on this project when determining the environmental harm of the project and in consideration of the public interest.

• Due to climate change, the Great Lakes region is already warming faster than the rest of the country, affecting flooding, extreme weather, and wildlife.
• Lake Michigan has experienced increased flooding that will inevitably continue. The application should consider these impacts as it pertains to environmental protection, as it will affect the project site and construction’s impact to the flora and fauna in the area.
• The construction and operation of the Line 5 tunnel will also create their own greenhouse gas emissions, part of the cumulative impacts the Corps should consider. Greenhouse gas emissions have a measurable impact our health, our economic activity, our quality of life, and our overall well-being, by exacerbating climate change.
• Continuing the transport of light crude oil and natural gas for 99 years is not in the public interest, especially when the State of Michigan is supposed to get to carbon neutrality by 2050.

Third, Enbridge’s alternatives analysis also falls short because it presumes that the only option for reducing the odds of a spill in the Straits is to construct a tunnel for the pipeline carrying light crude oil and does not explore other options that would reduce the environmental risk to the Straits. A full EIS must explore all of this in greater depth than the application.

Lastly, the Corps should reject Enbridge’s application because it interferes with cultural resources. Since the last comment deadline, a team discovered evidence of historical tribal assets and artifacts on the bed of the Straits, possibly dating from the last ice age. There should be a full examination and protection for these resources, which have great cultural value for current and future generations. Construction of the tunnel would interfere with these priceless resources.

Overall, Enbridge fails to provide adequate information in its application and fails show in that dearth of information that Enbridge will be able to comply with Section 404 of the Clean Water Act or Section 10 of the Rivers and Harbors Act. Due to the inadequate analysis on cumulative impacts and alternatives, combined with the great harm to the environment and the public interest, among the numerous concerns voiced by other commenters, we ask that the Corps reject Enbridge’s permit application as proposed.

ELPC is working on multiple fronts to protect the Great Lakes. We have submitted comments to Michigan’s Department of Environment, Great Lakes, and Energy on additional Enbridge permit applications, and you can read more about our work with the Michigan Climate Action Network before the Michigan Public Service Commission here.