Enbridge’s Proposed Oil Tunnel Would Significantly Affect and Endanger Human Environment

FLOW Executive Director Liz Kirkwood made the following statement during a U.S. Army Corps of Engineers public hearing on Monday, December 7, regarding the environmental impact of Enbridge’s proposed oil tunnel under the Straits of Mackinac.

The National Environmental Policy Act mandates Environmental Impact Statements (EISs) for all major projects that significantly affect the environment.

The proposed tunnel is, categorically, a major project and it will significantly affect and endanger the human environment. The scale, wetlands fill, landscape alternation, nearshore habitat, massive water withdrawal and chemical discharge of wastewater, and spoils represent both a major project and significant effects to the human environment.  I want to enumerate eight reasons why a full EIS is required to evaluate this proposed project.

1. The location of the tunnel is in the heart of the largest and most valuable fresh surface water system in the world.
2. The proposed project meets all 10 of the “intensity” factors indicating “severity of impact” under 40 C.F.R. § 1508.27.  Meeting just one of these intensity factors can necessitate an EIS.
3. The applicant indicates that the construction of the project will use 5 water treatment additives for slurry conditioning, including bentonite, soda ash, carbon dioxide, sulfuric acid, and a flocculant/coagulant for removing suspended solids.  Enbridge notes that “additional polymer-based additives may be needed.”  The Corps must determine the composition of these additives and the risk posed by the use of all of these chemicals
4. The proposed project will fill coastal wetlands – among the most biologically productive areas in the world – over 90 percent of the roughly 200 fish species that occur in the Great Lakes are dependent on coastal wetlands.
5. Independent experts who studied Enbridge’s proposed tunnel plan concluded that it “raises serious concerns regarding the feasibility, integrity, and planning for the construction of the tunnel.”  More than 75 percent of the tunnel boring area is in “very poor” or “poor” quality rock conditions, the experts warned, also citing the potential for explosions because of the presence of methane gas.
6. The State Historic Preservation Office has given notice that the recently disclosed evidence of potential submerged prehistoric sites requires a full evaluation.
7. At this point in time, Enbridge has yet to issue a credible estimate of project cost.  The original estimate of $500 million was for a tunnel with a 10 ft diameter.  The proposed project would have an 18 – 21 ft diameter requiring the excavation and disposition of four times the material compared to the original proposal.
8. Enbridge is explicit in indicating that the proposed project would extend the life of Line 5 for 99 years.  It will transport 23 million gallons of oil and natural gas liquids daily, that when burned, will yield over 57 million metric tons of atmospheric carbon annually – more carbon than is emitted by the nation’s 3 largest coal plants combined.  This long-term investment in fossil fuel infrastructure is directly at odds with the broad scientific consensus that immediate steps must be taken to decarbonize the economy to avoid the most catastrophic effects of climate change.

It is difficult to conceive of a project more worthy of a full environmental statement.