FLOW to U.S. Army Corps: Oil Tunnel in the Great Lakes Is Not a Solution


Editor’s note: The following are comments made by FLOW Deputy Director Kelly Thayer on September 8, 2022, in St. Ignace, Michigan, at a public meeting of the U.S. Army Corps of Engineers (Army Corps). The Army Corps, Detroit District, held the session to help set the scope of its environmental impact statement (EIS) study of a proposal by Enbridge, Inc., of Canada, to build an oil tunnel under the Straits of Mackinac to house its Line 5 oil pipeline, which carries oil from western Canada primarily to refineries in Sarnia, Ontario.

Tribal Nations, agencies, communities, organizations, citizens, and other stakeholders can comment on the tunnel proposal through Oct. 14, 2022, via mail, through the Army Corps project website, or at the Army Corps’ Oct. 6, 2022, online meeting. The Oil & Water Don’t Mix campaign, of which FLOW is a founding steering committee member, also is collecting and forwarding comments to the Army Corps using an email template that suggests key points to make.

Learn more about FLOW’s efforts to shut down Line 5 and stop the proposed oil pipeline tunnel on FLOW’s Line 5 program page and new Line 5 fact sheet.


Good evening. My name is Kelly Thayer. I am Deputy Director of the nonprofit organization For Love of Water or “FLOW”, the Great Lakes law and policy center located in Traverse City, Michigan.

Kelly Thayer, FLOW Deputy Director

Thank you to Commander Boyle and the U.S. Army Corps of Engineers, Detroit District, for this opportunity to comment. FLOW has supporters throughout the Great Lakes Basin, including right here in St. Ignace. They rely on us to ensure that the Great Lakes remain healthy, public, and protected for all.

Simply put, the Straits of Mackinac is the worst possible place to build and operate an oil pipeline tunnel. Any rupture, explosion, or other event resulting in a major oil spill in the Straits would contaminate the very heart of the Great Lakes, which hold 95% of the fresh surface water in the United States.

Simply put, the Straits of Mackinac is the worst possible place to build and operate an oil pipeline tunnel. Any rupture, explosion, or other event resulting in a major oil spill in the Straits would contaminate the very heart of the Great Lakes, which hold 95% of the fresh surface water in the United States.

In the best case scenario, Enbridge-contracted, oil spill response teams would be able to remove no more than 30% of the oil from such a spill.

With this in mind, the Army Corps’ Environmental Impact Statement or “EIS” review of the project should be scoped to eliminate the risk of a pipeline-related oil spill into the Great Lakes.

Unfortunately, the draft purpose and need statement limits the range of risk-elimination options by focusing only on connecting Enbridge’s existing North Straits Facility and Mackinaw City pump station. The purpose and need statement should be revised to eliminate these geographic constraints and focus more generally on liquid-petroleum product transportation solutions to approximate the existing capacity of Line 5.

The draft purpose and need statement’s language regarding the minimization of environmental risks is not specific enough in the context of project-related oil spills. The statement should be revised to include both minimizing environmental risks and avoiding any risk of a pipeline-related oil spill into the Great Lakes.

The environmental study’s focus “should be revised to include both minimizing environmental risks and avoiding any risk of a pipeline-related oil spill into the Great Lakes.”

The alternatives analysis must include, at a minimum:

  1. A no action alternative that would use existing capacity in other pipelines and, if necessary, other transportations solutions–such as rail and truck transport of natural gas liquids–in lieu of building new pipeline infrastructure.
  2. An alternative to connect Enbridge’s Superior, Wisc., and Sarnia, Ontario, terminals without crossing the Great Lakes.
  3. A tunnel alternative that fully eliminates the risk of oil intrusion into the Straits in the event of an explosion or similar event.

The relative risks of the proposed oil tunnel project don’t matter when Enbridge is unlawfully operating the existing oil pipelines in the Straits.

In performing this alternatives analysis, the EIS must evaluate the environmental risks of the proposed project independently of Enbridge’s existing oil pipeline infrastructure in the Straits.

Nearly two years ago, the State of Michigan revoked and terminated the 1953 Easement that allegedly authorizes Enbridge to occupy state bottomlands. The relative risks of the proposed oil tunnel project don’t matter when Enbridge is unlawfully operating the existing oil pipelines in the Straits.

FLOW looks forward to submitting written comments by the October 14, 2022, deadline, in addition to these preliminary, verbal comments.

In short, we recommend that the Army Corps scope its EIS review of the oil tunnel project to eliminate the risk of a pipeline-related oil spill into the Great Lakes, which provide drinking water for millions of people in the United States and Canada, drive our economy, and define our way of life. Thank you.

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