Last Chance to Speak Up: Reject Enbridge’s Line 5 Tunnel

Reject the Line 5 Tunnel Permit

To the Michigan Department of Environment, Great Lakes, and Energy: I urge EGLE to reject Enbridge’s request for a National Pollutant Discharge Elimination System permit for the proposed Line 5 tunnel project. Because of the proposed discharge volume, duration, pollutant and treatment uncertainty, receiving-water sensitivity and cumulative impacts the public-interest means that EGLE cannot legally authorize a NPDES permit for this proposed tunnel project. This permit is not routine construction paperwork. It would authorize Enbridge to discharge up to nearly 7 million gallons per day of industrial construction wastewater into Lake Michigan, including up to 5 million gallons per day from Mackinaw City, 1 million gallons per day from St. Ignace, nearly another million gallons per day of hydrostatic test water, and additional stormwater discharges. At maximum authorized rates, that could mean roughly 2.19 billion gallons of wastewater entering the Great Lakes each year. The wastewater covered by this permit would come from tunnel boring, shaft excavation, slurry handling, groundwater seepage, hydrostatic testing, and other major construction activities. Enbridge’s own application identifies pollutants and water-quality concerns, including suspended solids, dissolved solids, chlorides, oil and grease, temperature changes, and pH changes. These discharges could cloud Great Lakes waters, smother habitat, stress fish and other aquatic organisms, alter water chemistry near discharge points, and degrade one of the world's most ecologically sensitive freshwater passages. EGLE should also reject the permit, which leaves critical questions unresolved. The application contemplates water treatment additives, including possible biocides, flocculants, water conditioners, and pH-adjusting agents, but those chemicals would be submitted separately for approval. The public should not be asked to comment on an incomplete permit when the full list of chemicals, concentrations, and potential impacts on Lake Michigan has not been disclosed. EGLE also requested more information about drilling fluids, bentonite clay, intake design, pump capacity, screen dimensions, and through-screen velocity, all of which go directly to whether aquatic life and water quality can be protected. Finally, Enbridge is also seeking authorization to withdraw up to 2 million gallons per day of water directly from Lake Michigan for industrial use. Intake systems can harm fish, eggs, larvae, and other aquatic life through impingement and entrainment. EGLE should not approve first and ask questions later. Enbridge must prove through full public review that its wastewater discharges, chemical additives, slurry materials, sediment, oil and grease, and water withdrawals will not harm Lake Michigan or the Straits of Mackinac. EGLE should reject this permit and protect the Great Lakes from an unnecessary and dangerous tunnel project.