FLOW’s work is guided by sound science, policy, and law to protect the Great Lakes for current and future generations. Below you will find in-depth reports, articles, and resources from FLOW and partner organizations about key Great Lakes issues, FLOW’s programs, and the Public Trust.
Aquaculture
Public Comment - 2022
- FLOW Public Comment to the Ohio DNR on the AquaBounty Farm Ohio LLC Water Withdrawal and Consumptive Use Permit Application--East Well Field, 9-16-2022
- FLOW Public Comment on the AquaBounty Farm Ohio LLC Water Withdrawal and Consumptive Use Permit Application, 02-22-22
Public Comment - 2021
Handouts
Reports - 2016
Reports - 2015
Additional Information
Beaches and Coastal Issues
Handouts
Reports - 2012
Beach Grooming in Michigan: What the New Beach Grooming Law Means for Littoral Stewards and How to Protect your Beach While Still Fulfilling Your Responsibilities as a Steward of the Great Lakes August 1, 2012
Bottled Water, Diversions, and Exports
Reports - 2024
- A Watershed Moment: The Great Lakes Compact After 15 Years, April 16, 2024
Public Comments, 2022
- Consumers Energy water withdrawal permit application, April 18, 2022
Handouts
Reports - 2021
Reports - 2020
EGLE to NESTLÉ Permit 1701, PW 101, Osceola Township, Proposed Monitoring Plan and Joint Agreement January 30, 2020Reports - 2019
FLOW Amicus Brief on Foxconn Contested Case March 5, 2019Reports - 2018
FLOW Racine/Foxconn Diversion Comment to the Regional Body and Council May 3, 2018Reports - 2017
FLOW Letter to the MDEQ re: Nestle Permit Application November 13, 2017 FLOW Letter and Expert Report to the MDEQ re: Nestle Application April 21, 2017 FLOW Comments to the MDEQ re: Nestle Application April 12, 2017 FLOW Letter to the MDEQ re: Lack of Adequate Information and Extension February 22, 2017Reports - 2016
FLOW Comments to the MDEQ re: Nestle Permit Procedural Flaw December 16, 2016 FLOW Comments to the MDEQ on Nestle Permit, November 3, 2016 FLOW Comments to the Regional Body on the Waukesha Diversion Application, March 1, 2016 Waukesha's Proposed Exemption to the Great Lakes Compact Diversion Ban: A Time for Utmost Caution, Jim Olson, June 8, 2016Reports - 2015
FLOW Comments to Wisconsin DNR on the Waukesha Diversion Application, August 28, 2015Additional Information
Climate Change
Comments - 2022
Reports - 2013
- FLOW Comment to the International Joint Commission on the draft “Building Collaboration Across the Great Lakes – St. Lawrence River System: An Adaptive Management Plan For Addressing Extreme Water Levels, April 15, 2013
- Overview of FLOW's 2013 Water Levels Program
- FLOW Op-Ed: Climate Change is Taking Our Water February 24, 2013
- Letter to Governor Snyder Regarding Great Lakes Water Levels and Emergency Dredging February 19, 2013
Reports - 2012
- FLOW Comment to the International Joint Commission On Water Level Plans for Great Lakes and Public Trust Principles September 30, 2012
- FLOW Press Release: FLOW Proposes New Principles to IJC for Addressing Low Water Levels October 24, 2012
Additional Information
Confined Animal Feeding Operations (CAFOs)
Environmental Justice
Fracking Protective Ordinances in Michigan
Existing Ordinances
- Mayfield Township (Lapeer County) (moratorium)
- Rochester Hills (moratorium)
- West Bloomfield (moratorium)
- Edwards Township (DRAFT road franchise)
- Mayfield Township (injection wells)
Reports - 2014
- FLOW’s Comments re: MDEQ Proposed New Rule Changes to Address Unconventional and Horizontal Hydraulic Fracturing July 31, 2014
Reports - 2013
- Comment and Recommendations to Michigan DNR and NRC on Law and Policy for State Land Leases within the “Holy Waters” Area of the AuSable River and Manistee River Watersheds December 10, 2013
- FLOW Comments to the University of Michigan Graham Sustainability Institute's Integrative Assessment Report Series on Hydraulic Fracturing in Michigan October 7, 2013
Reports - 2012
- FLOW Report: Horizontal Fracturing for Oil and Gas in Michigan: Legal Strategies and Tools for Communities and Citizens November 2012
- FLOW Comments to Michigan Department of Natural Resources on Hydraulic Fracturing and State Land Leases September 11, 2012
- Wisconsin Farmers and Towns Turned Upside Down by Frac Sand Mining for Oil and Gas Development: Are Michigan’s Vast Dunes and Sand Reserves Next? July 17, 2012
- Out of Sight and out of Mind, or so we hoped: How the American Regulatory Process July 1, 2012
Additional Information
Groundwater
Policy Brief: The Case for a Statewide Septic Code in Michigan - April 25, 2024
Policy Brief: Polluter Accountability in Michigan - April 16, 2024
Amicus Brief 9.20.23 - MICHIGAN FARM BUREAU, et al., v. MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
Policy Brief: Polluter Accountability in Michigan - April 16, 2024
Amicus Brief 9.20.23 - MICHIGAN FARM BUREAU, et al., v. MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
Reports - 2023
Reports - 2022
Reports - 2021
Infrastructure
Stormwater Utilities
- Stormwater Utilities Brief -- Poor stormwater infrastructure can lead to problems such as water pollution, algal blooms, beach closures, threats to public health, and increased infrastructure costs to taxpayers. Polluted runoff also contaminates the environment and endangers aquatic life. Stormwater utilities can be a part of the solution, by enabling communities to fund modern, green stormwater infrastructure and protect the environment and public health. Learn more!
Invasive Species
Reports - 2014
- Joint Letter/Comments to the U.S. Army Corps of Engineers regarding the Great Lakes Mississippi River Interbasin Study (GLMRIS) March 31, 2014
Additional Information
Line 5 Pipelines and Proposed Tunnel
Handouts
- January 2024 Line 5 Fact Sheet
- Line 5 Key Facts
- Line 5 Alternatives Fact Sheet
- Line 5 Propane Fact Sheet
- Protecting the Heart of the Great Lakes from a Disastrous Oil Spill
Comments, Reports, and Briefs
- FLOW and Great Lakes Business Network Amicus Brief with the Sixth Circuit Court of Appeals, asking the court to overrule denial of Gov. Whitmer's motion to dismiss Enbridge v. Whitmer (PDF) | October 22, 2024
- FLOW Appellant Reply Brief to Enbridge Energy re: Application of Enbridge Energy to Replace & Relocated Line 5 (PDF) | October 3, 2024
- FLOW Appeals MPSC Decision Approving the Line 5 Tunnel: FLOW Files Appellate Brief with Court of Appeals (PDF) | April 12, 2024
- Nessel v. Enbridge: Oral arguments in the U.S. Court of the Appeals for the Sixth Circuit | March 21, 2024
- Federal Court Hears Arguments from Bad River Band and Enbridge in Appeal of Line 5 Pipeline Shutdown Order | February 8, 2024
- FLOW Appeals MPSC Permit to Site Replacement Line 5 Pipeline in Proposed Great Lakes Tunnel | January 4, 2024
- MPSC Approves Permit for Enbridge Tunnel in the Straits of Mackinac; Breaches Legal Duty to Protect Michigan’s Natural Resources - FLOW's statement | December 1, 2023
- FLOW's summary of the PLG Consulting report, Likely Market Responses to a Potential Shutdown of LINE 5 | November 17, 2023
- FLOW public comments to the Mackinac Straits Corridor Authority | June 2, 2023
- FLOW EIS Scoping Comments to US Army Corps on Proposed Line 5 Tunnel 10-14-2022 and Great Lakes Business Network-Amicus Brief-Bad River Band v Enbridge 6-16-2022
- FLOW Comments Submitted to the Michigan Public Service Commission on the Enbridge-Proposed Line 5 Oil Tunnel through the Straits of Mackinac—July 7, 2022
- FLOW to Michigan Public Service Commission: No Enbridge Oil Tunnel Without Authorization Under Public Trust Doctrine—March 16, 2022
- Amicus Brief of For Love of Water in Support of Defendants' Opposition to Plaintiffs' Motion for Summary Judgment—March 15, 2022
- Reply Brief of Intervenor FLOW, filed with the MPSC, on the Failure of Enbridge to Obtain the Legally Warranted Interest in the State-Owned Bottomlands Required by Michigan’s Public Trust Law and to Comply with the Duties Imposed by the Michigan Environmental Protection Act—March 11, 2022
- Initial Brief of MPSC Intervenor For Love of Water (FLOW) on Proposed Oil Tunnel—Feb. 18, 2022
- FLOW to Mackinac Straits Corridor Authority: No Enbridge Oil Tunnel Without Authorization Under Public Trust Doctrine—February 14, 2022
2021
- FLOW Letter to MSCA—September 20, 2021
- MPSC Case No. U-20763:
- MPSC Brief on Remand—January 15, 2021
2020
- Supplemental Comments to USACE permitting on proposed tunnel—December 15, 2020
- Comments to EGLE on Application for Line 5 Tunnel—October 19, 2020
- Comments to USACE permitting on proposed tunnel—July 14, 2020
- Public Comment to MPSC on Enbridge Request for Declaratory Relief in its Application for Approval—May 13, 2020
- FLOW and Straits of Mackinac Alliance's formal legal comments to EGLE—May 1, 2020
- MPSC Case No. U-20763: Application for the Authority to Replace and Relocate the Segment of Line 5 Crossing the Straits of Mackinac into a Tunnel Beneath the Straits of Mackinac—April 17, 2020
- FLOW MPSC Appeal ALJ Ruling—November 6, 2020
- Response to Enbridge Energy, Limited Partnership’s Motion in Limine—September 23, 2020
- Reply to Enbridge’s Objections to Petition to Intervene Proof of Service—August 12, 2020
- Public Comments of FLOW—May 13, 2020
- Appearance of FLOW and Petition for Permissive Intervention—May 1, 2020
- FLOW Comments on the Upper Peninsula Energy Task Force Draft Propane Report—April 6, 2020
- FLOW Letter to Mackinac Straits Corridor Authority—March 5, 2020
2019
- FLOW Amicus Curiae Brief in support of plaintiff's motion for summary disposition -- December 4, 2019
- FLOW Comments on Enbridge's Violations of the 1953 Easement for the Line 5 Oil Pipelines in the Straits of Mackinac and Lake Michigan—November 12, 2019
- FLOW Amicus Brief in Support of State Defendants—September 10, 2019
- Letter and Legal Memorandum on the Great Lakes Submerged Lands Act and Public Trust Doctrine—May 13, 2019
- Legal Memorandum for Formal Opinion of the Attorney General—February 8, 2019
- Report on the Inadequacy of Enbridge Financial Assurances to the State of Michigan—January 29, 2019
2018
- Public Comments on Public Act 359 and Line 5 Agreements—December 18, 2018
- Public Comments on the Joint Application of Enbridge Energy to Drill 24 Geotechnical Borings in the Great Lakes Bottomlands—December 3, 2018
- Oil Spill Economics: Addendum A: Multibillion dollar Economic Impact to Great Lakes Shipping, Steel Production, and Jobs—November 20, 2018
- FLOW Letter to Mackinac Bridge Authority on State and Enbridge Proposal—November 1, 2018
- FLOW Letter Regarding Approvals Required for Proposed Tunnels in St. Clair River and Straits of Mackinac—September 28, 2018
- Public Comments on State Independent Draft Risk Analysis—August 17, 2018
- Public Comments on the Joint Application of Enbridge Energy for Anchor Screws for Line 5 Pipelines in the Straits of Mackinac—July 19, 2018
- Public Comments on Enbridge's Studies Required by the November 2017 Agreement—July 15, 2018
- Letter on State of Michigan's Authority on Line 5—May 24, 2018
- Public Comments on the Joint Application of Enbridge Energy for 48 New Anchor Screws for Line 5 Pipelines in the Straits of Mackinac—May 11, 2018
- Oil Spill Economics: Estimates of the Economic Damages of an Oil Spill in the Straits of Mackinac in Michigan—May 2, 2018
- Letter to MPSC and DEQ on New or Altered Structures of Line 5—April 11, 2018
- Supplemental Comments on 2017 Anchor Permit Application—February 9, 2018
2017
- FLOW Public Comments on Dynamic Risk Final Alternatives Analysis Report—December 22, 2017
- FLOW Letter re: Pitting Corrosion and Impacts of Mussels on Bare Steel Pipelines—November 3, 2017
- FLOW Supplemental Comments on Enbridge Anchor Permit Application—October 12, 2017
- FLOW Comments on Draft 2017 Lake Huron Lakewide Action and Management Plan—Sept. 5, 2017
- FLOW Comments on the Dynamic Risk Draft Alternatives Analysis—August 4, 2017
- Supplemental Comments on the Joint Application of Enbridge Energy to Occupy Great Lakes Bottomlands for Anchoring Supports—August 4, 2017
- Media Release: Reject Anchor Permit—July 25, 2017
- Media Release: Alternatives Analysis Flawed—July 24, 2017
- Comments on the Joint Application of Enbridge Energy to Occupy Great Lakes Bottomlands for Anchoring Supports—June 29, 2017
- Public Comment to Pipeline Advisory Board—June 12, 2017
- Oil & Water Don't Mix letter reply—March 27, 2017
- Final Letter to State of Michigan re: Enbridge Corrosion Violations—March 9, 2017
- State of Michigan Letter to Oil and Water Don't Mix—March 8, 2017
- State of Michigan Letter to Enbridge with Request for Information—March 8, 2017
- Letter to US Forest Service re: Reissuance of the Enbridge Special Use Permit across National Forest Lands of Chequamegon-Nicolet National Forest—January 6, 2017
2016
- Oil & Water Don't Mix Sign-on Letter to DEQ re: Enbridge permit request—September 9, 2016
- FLOW Public Comments Objecting to Enbridge's Application to DEQ & Corps for Anchoring Supports—August 24, 2016
- Appendix A
- Appendix B
- Technical Note Regarding Enbridge Line 5 Non-Compliance with 1953 Easement Requirements, A Mechanistic Analysis of Straits Pipeline Washout Phenomena, by Edward E. Timm, PhD, PE—August 20, 2016.
- Oil & Water Don't Mix Standing Sign-on Letter to DE re: Enbridge Permit Reques —Aug. 28, 2016
- FLOW & Oil & Water Don't Mix Sign-On Letter to the State—April 13, 2016
2015
- FLOW Expert Report: Eliminating the Line 5 Oil Pipeline's Unacceptable Risk to the Great Lakes through a Comprehensive Alternatives Analysis and Systems Approach,—December 14, 2015
- FLOW Expert Report on Oil Transport in the Great Lakes, with Supplemental Comments on the Michigan Petroleum Pipeline Task Force's July 2015 Report—September 30, 2015
- Michigan Petroleum Pipeline Task Force Report—July 2015
- FLOW Expert Report to the Michigan Petroleum Pipeline Task Force on Line 5—April 30, 2015
2014
Marinas
- FLOW's comments to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), RE: 61-1204 West Western - Muskegon Permit # HQO DZGT-7AS2A New pier system at Hartshorn Park/Marina. May 10, 2024.
- Comments and concerns regarding the application for the proposed construction of a boathouse, boat basin, and dredged entrance channel on the 3-acre lakefront property located at 121 N. Long Lake Road, Traverse City, Michigan (PDF). November 11, 2023.
- FLOW's comments to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) and the U.S. Army Corps of Engineers, RE: Proposed Crib Pier, R. Mampe/Omena Blue Moon LLC, 3388 Omena Point Rd., Omena, EGLE, WRD #HPT-45R7-1C96K, U.S. ACE No. LRE-2023-00371-56-R23, Section 36, T31N, R11W, Leelanau Township, Leelanau County, Michigan. September 11, 2023.
Nuclear Energy
Reports - 2017
FLOW Letter on Fermi 2 Power Plant in Newport, Michigan July 9, 2018
Public Lands
Reports & Legal Comments —2022
FLOW's Public Comments on the 162,000-acre Camp Grayling Lease Expansion Proposal submitted to the Michigan Department of Natural Resources and the Michigan Natural Resources Commission—Aug. 31, 2022
The Public Trust
Michigan Public Water Trust Act - Model Legislation
FLOW (For Love of Water) has developed model legislation to protect water quality, advance water equity, ensure that the waters of the State remain a public resource, and provide communities and water utilities with a steady source of funding to address water affordability and infrastructure needs.
Handouts
Reports - 2017
- A Nonpartisan Comment on Proposed Senate Bill 409 and the Public Trust Doctrine December 5, 2017
- Public Comment on the Review of Thunder Bay Marine Sanctuary August 14, 2017
Reports - 2014
Reports - 2013
- FLOW Comments to IJC on Water Levels, September 30, 2012
- Memorandum on the Energy Water Nexus for Michigan's Energy Policy Future
- FLOW Comment to the International Joint Commission on the draft "Building Collaboration Across the Great Lakes - St. Lawrence River System: An Adaptive Management Plan For Addressing Extreme Water Levels" April 15, 2013
- FLOW Comments to Ontario Legislature Regarding Bill 6, Great Lakes Protection Act October 31, 2013
Reports - 2012
- Report: Horizontal Fracturing for Oil and Gas in Michigan: Legal Strategies and Tools for Communities and Citizens November 30
- Great Lakes Water Quality Agreement Comments October 13
- Comment to the International Joint Commission On Water Level Plans for Great Lakes and Public Trust Principles September 30
- Comments to Michigan Department of Natural Resources on Hydraulic Fracturing and State Land Leases September 11
- Natural Resource Defense Council Report Illustrates Great Lakes Failures in Providing Access to Public Trust Water August 1
- Beach Grooming in Michigan: What the New Beach Grooming Law Means for Littoral Stewards and How to Protect your Beach While Still Fulfilling Your Responsibilities as a Steward of the Great Lakes August 1
- Wisconsin Farmers and Towns Turned Upside Down by Frac Sand Mining for Oil and Gas Development: Are Michigan’s Vast Dunes and Sand Reserves Next? July 17
- Out of Sight and out of Mind, or so we hoped: How the American Regulatory Process Has Failed to Protect the Public Trust from Underground Injection Wells July 1
- Analysis of Ohio House Bill 473 May 17
- Comments on the Draft National Ocean Policy Implementation Plan February 27
- Natural Resource Defense Council Report Illustrates Great Lakes Failures in Providing Access to Public Trust Water August 1, 2012
- Analysis of Ohio House Bill 473 May 17, 2012
Reports - 2011
- Report to IJC on Public Trust Principles November 30, 2011
Additional Information
The Water, Food, Energy, Climate Change Nexus
Reports - 2015
- FLOW Comments on Draft Ten Year Review of the IJC's Report on Great Lakes Basin Waters June 30, 2015
Reports - 2013
- Memorandum on the Draft Renewable Energy Report for Michigan's Energy Policy Future October 16, 2013
- Memorandum on the Energy Water Nexus for Michigan’s Energy Policy Future April 22, 2013
- FLOW Comments to the International Joint Commission on the draft Lake Erie Ecosystem Priority ("LEEP") Report: Scientific Findings and Policy Recommendations to Reduce Nutrient Loadings and Harmful Algal Blooms October 5, 2013
- Executive Summary of Comments to the International Joint Commission on the draft Lake Erie Ecosystem Priority ("LEEP") Report October 6, 2013
Reports - 2012
- FLOW Comments on the Great Lakes Water Quality Agreement October 13, 2012
Toxics and Contamination
- ATSDR Petition for a Public Health Assessment (PHA) due to significant historic, current, and ongoing air, water, and drinking water contaminant exceedances from BASF, Inc., Wyandotte, Michigan ( EPA FACILITY ID: 110000494019, RCRA MID 064197742) -- February 29, 2024
Water Levels
Reports - 2013
Reports - 2012
Wetlands Destruction
Reports - 2018
- Comments on Wetlands, Lakes and Streams Application Submitted by Aquila Resources, Inc. Back 40 Open Pit Sulfide Mine February 2, 2018
