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Add your name to these public comments to be submitted to Michigan state agencies by signing this petition.

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Last June, the preliminary Line 5 Alternatives Study was released, and more than 23,000 people submitted their comment calling for the shutdown of Line 5 as the only alternative that will truly protect the Great Lakes from an oil spill. The revised and final Alternatives Study has just been released, which has triggered a second comment period that is now open.

Prevent a Catastrophic Great Lakes Oil Spill

The deadline for public comments is December 19, 2017, so please sign on and submit your comment today via this online form. Let's prevent a devastating oil spill in the Straits of Mackinac.

To the Michigan Department of Environmental Quality, Michigan Agency for Energy, Michigan Department of Natural Resources, Michigan Governor, Michigan Attorney General, and Michigan Pipeline Safety Advisory Board:

I am writing to submit my official comment in response to the State of Michigan’s Line 5 final alternatives analysis dated October 26 and released on November 20. I am deeply disappointed in this final analysis. A draft alternatives report released in June was riddled with errors and omissions, and the final report contains most of the same failures.

This report fails to meet its overall purpose of “providing the State of Michigan and other interested parties with an independent, comprehensive analysis of alternatives to the existing Straits Pipelines, and the extent to which each alternative promotes the public health, safety, and welfare and protects the public trust resources of the Great Lakes.”

It lacks credibility because its author is Dynamic Risk, a firm with ties to Enbridge, the Canadian energy transport company that owns Line 5. Even worse, it absurdly underestimates the impact of a spill and ignores a viable alternative to Line 5 – use of existing infrastructure. An independent expert review in December 2015 documented the practicality of this alternative.

Decommissioning Line 5 in the Straits of Mackinac is the only alternative that will prevent an oil spill with catastrophic consequences for the Great Lakes and the State of Michigan. Moreover, this final alternative report affirms that decommissioning is a feasible option with zero risks to the Great Lakes and minimal economic impacts to Michigan customers (e.g., two cents more at the gas pump and roughly 10 to 25 cents more for propane in the Upper Peninsula). 
 
It is time for the state to reject the flawed study, exercise its affirmative legal duty as public trustee of the Great Lakes and bottomlands, and shut down Line 5. The state should use that authority to revoke the 1953 easement agreement that Enbridge has consistently violated.

The risk of a spill is too great to allow Line 5 to continue to operate in the Great Lakes. Our state government should not put the Great Lakes, our economy, health, drinking water, fisheries, and way of life at risk from a catastrophic oil spill any longer. In fact, on November 16, the Coast Guard Coast commandant testified again to Congress that his agency is not prepared to clean up a large-scale pipeline oil spill in the Great Lakes.

I urge you to act as public trustees of our waters and bottomlands, enforce the easement in light of Enbridge’s ongoing violations, and begin the process of decommissioning Line 5 in the Straits of Mackinac to protect the Great Lakes from a catastrophic oil spill. The State of Michigan has a legal duty to take this enforcement action. Enbridge’s ongoing violations cannot be remedied. It is time for the state to act decisively and with urgency.

Specifically, the draft report on alternatives to Line 5 in the Mackinac Straits:

  1. Fails to follow the recommendations and standards outlined in the Michigan Petroleum Pipeline Task Force Report, which resulted from a process created by the governor and co-chaired by the attorney general, and therefore cannot be used by the State of Michigan “in making decisions about the future of the Straits Pipelines.”
  2. Neglects to provide the state with an independent, fair analysis of the alternatives to Line 5 as required by the Task Force Report. This final report remains biased toward allowing Line 5 to continue to operate and/or allowing Enbridge to build new oil infrastructure in the Straits of Mackinac and further expand its operations. That bias grows out of past, and potentially future, business relationships between Enbridge and the report’s authors.
  3. Fails to analyze existing pipeline infrastructure as an alternative to Line 5 in the Straits, which the state required Dynamic Risk to analyze, and leaving it out conflicts with Task Force recommendation 3 (b). It is unacceptable that the contractor eliminated this alternative without any analysis. The 1953 easement granted with strict conditions by the state to Enbridge does not guarantee transport of 540,000 barrels per day (bpd) of oil and natural gas liquids. In fact, the 1953 MPSC Order states 300,000 bpd, which means Enbridge is currently operating Line 5 at 80 percent over design capacity. 
  4. Fails to analyze new evidence disclosed by Enbridge affecting the pipeline’s integrity, including external corrosion, 48 bare metal spots caused by the installation of screw anchors, compromised cathodic protection, and historic excessive pipeline spans greater than the 75-feet limit (including a 286-foot span that was unsupported for years), as required by the legal operating agreement with the State of Michigan. Dynamic Risk’s rationale, in part, is that "it would be inappropriate to speculate on any of the above aspects of the coating condition."
  5. Fails to consider tribal sovereign treaty rights and feedback on the basis that Dynamic Risk was not a party to tribal and state consultations, which is an unacceptable dismissal of input by a key stakeholder. 
  6. Grossly underestimates the total economic spill costs at between $147 million and $310 million, when Enbridge’s cleanup costs of its 2010 Line 6B pipeline oil spill along a 40-mile stretch of the Kalamazoo River cost more than $1.2 billion.
  7. Overestimates an impact to propane supply, greatly exceeding what independent experts have determined would be necessary to provide the Upper Peninsula’s Rapid River facility with an alternative supply. The flawed report finds that up to 35 railcars per week or 15 truckloads per day would be necessary, while another study found it would take only one railcar or 3 - 4 truckloads per day to replace the Line 5 propane supply to the U.P.
  8. Continues to show an unfair bias towards building a tunneled pipeline in the Mackinac Straits. The report estimates a much lower cost for a tunnel than other estimates for this type of infrastructure; it fails to consider the risk of a spill to the Great Lakes, rivers and streams from other portions of the 64-year-old pipeline if the Straits portion were rebuilt. Dynamic Risk prefers new pipelines, which was evident when the firm aggressively promoted building a tunnel in its proposal to do this report, and its analysis is deeply flawed.

 

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Showing 1703 reactions

  • @susanpankhurst tweeted link to this page. 2017-12-12 20:06:36 -0500
    JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5. http://www.oilandwaterdontmix.org/submit_your_line_5_comment?recruiter_id=1679
  • signed 2017-12-12 20:06:16 -0500
    Please listen to “we the people” who want this pipeline shut down to protect our water, health, and way of life.
  • signed 2017-12-12 20:00:27 -0500
    The major" Dilbit" disaster of 2010 in the Kalamazoo River would seem minor by comparison to a Macinac straits rupture should the outdated dilapidating pipeline do likewise. Please find an alternative.
  • signed via 2017-12-12 19:44:38 -0500
    Line 5 has extended beyond its time limit & presents too much risk to Michigan natural resources & livelihoods, in addition to America’s greatest source of fresh water! SHUT IT DOWN NOW!!!
  • signed 2017-12-12 19:32:49 -0500
    As a citizen of Michigan I urge our Governor Attorney General and all state regulatory and environmental protective agencies to shut down Line 5 and to stand with the people of the state and protect this most valued resource. Do not wait until we are in the Clean up Phase.Do it now.
  • signed 2017-12-12 19:22:09 -0500
    Enbridge already provided Michigan with one massive oil spill in our Kalamazoo River. Their Line 5 Pipeline was built with an expected lifespan and they have gone way beyond this point. Enbridge has not been transparent about the condition of Line 5. There are several locations in the Straits where the pipe exceeds its unsupported free span; there are support structures which are tilted; thye have only recently admitted that protective coatings on several places are missing. We also have Enbridge’s recent admission that some parts of the pipe, where they can make the measurements, have lost 26% of its thickness. On top of this, we now have a behind-closed-doors deal with our Republican Governor. The parties offering assurances on this pipeline are all suspect. None of them have a good record of performance.
  • signed via 2017-12-12 19:15:18 -0500
  • signed 2017-12-12 18:59:33 -0500
    Shutdown line 5
  • signed 2017-12-12 18:51:19 -0500
    Please. Do not sell out the real value you’re dealing with here. Assume this line will fail—and during your lifetime. What’s at stake is utterly irreparable, irreplaceable. It needs your protection. We need you to protect it. Please: Step. up.
  • signed via 2017-12-12 18:46:09 -0500
  • signed 2017-12-12 18:02:47 -0500
    I support the views and comments made by Oil & Water Don’t Mix and the Tip of the Mitt Water Shed Council and feel that the only responsible action is to decommission line 5.
  • posted about this on Facebook 2017-12-12 17:55:09 -0500
    JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.
  • signed 2017-12-12 17:53:12 -0500
  • posted about this on Facebook 2017-12-12 17:06:02 -0500
    JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.
  • signed via 2017-12-12 17:05:41 -0500
    I am bitterly disappointed in Snyder’s acceptance of Enbridge’s “studies.” Just have that fox protect the hen house, boys. Snyder is obviously in for this for his own personal gain. The Great Lakes get wonderful lip service by Republicans, but like everything else the Republican Party is doing now, they are only for themselves. This 64 year old pipeline originally slated to last 50 years is in need of immediate shutdown. Period. Piping oil from Canada to Canada with huge personal risk is not good for Michigan.
  • signed via 2017-12-12 17:00:46 -0500
    Our Great Lake is worth more then the money we won’t receive (and who REALLY RECEIVES THAT MONEY??) from Enbridge. Our Governor will be gone from office..termed out..so for some reason (which I suspect has everything to do with his reward at the expense of Michigan) he has chosen to protect Enbridge interest instead of Michigan’s interest. It’s wrong…he should shut down Line 5 now!
  • posted about this on Facebook 2017-12-12 16:34:55 -0500
    JOIN ME and tell the State of Michigan the only acceptable way to protect the Great Lakes is to SHUTDOWN LINE 5.
  • signed 2017-12-12 16:34:45 -0500
    Line 5 is a disaster waiting to happen.
  • signed 2017-12-12 16:22:55 -0500
    Please shut line 5 down now. We have wind and solar and don’t need the out dated fossil fuel energy.
  • signed 2017-12-12 16:21:47 -0500
    Oil and Water Don’t mix! No to line 5!
  • signed 2017-12-12 16:01:17 -0500
    Shut it down NOW before it is too late!!!!
  • signed via 2017-12-12 15:53:44 -0500
  • signed 2017-12-12 15:44:38 -0500
    Pipeline spills continually occur, causing devastating damage to the environment. Since 1986 over 9,000 pipeline breaks have leaked over 4 million barrels of oil. Michigan has already suffered from oil contamination in the Kalamazoo River.
  • signed via 2017-12-12 15:25:08 -0500
    Please shut down Line 5 and continue studying the effects of a break on our great lakes – the thoughts of a leak are overwhelming. Please consider all those on the lakes and that depend on the lakes for survival. Can;t survive on lakes full of oil.
  • signed 2017-12-12 14:58:34 -0500
    Take down line 5 now!! No more bad Energy!

    Time for good decision making for our state!
  • signed 2017-12-12 14:51:27 -0500
    Amber Bowen
  • signed 2017-12-12 14:34:11 -0500
    These great lakes aren’t called “great” without reason. They are the lifeline for drinking water, food, and the very economy that keeps Michigan prospering. WHAT, exactly, is plan B should this precious lake die under our watch? What happens to a body of fresh water this size when it becomes unavailable for drinking, fishing, swimming and recreational activities?

    PLEASE close down line 5 before we are faced with these dire consequences.
  • signed 2017-12-12 14:23:07 -0500
    Please protect our most valuable resource….WATER!
  • signed 2017-12-12 14:01:04 -0500
    COMMENTS OF LEONARD PAGE

    MEMBER OF SACCPJE
    PUBLIC COMMENT HEARING, DECEMBER 12, 2017


    ON DYNAMIC RISK FINAL REPORT

    LITTLE BEAR ARENA, ST. IGNACE, MICHIGAN


    I WISH TO THANK THE PROFESSIONAL STAFF OF THE VARIOUS STATE AGENCIES AND THE MEMBERS OF THE PSAB FOR THEIR SERVICE. YOU HAVE SPENT MANY HOURS ON THIS LINE 5 ISSUE. HOWEVER, WE SHARE THE FRUSTRATION AT THE LACK OF PROGRESS AND THE SAD FACT THAT ANY PSAB RECOMMENDATIONSNOW PUSHED BACK UNTIL LATE NEXT YEARARE PROBABLY DESTINED TO BE IGNORED.


    WE HAD HOPED THAT THE WIDESPREAD AND DETAILED CRITIQUE OF JUNE DRAFT WOULD CAUSE DYNAMIC RISK TO CORRECT ITS MANY DEFICIENCIES. INSTEAD, DYNAMIC CHOSE TO SIMPLY RESTATE ITS CONCLUSIONS, BUT WITH EVEN HIGHER LEVELS OF ENGINEERING JARGON AS ITS SMOKESCREEN.
    DYNAMIC RISK HAS UTTERLY FAILED ITS PROMISE TO DO A COMPLETE, INDEPENDENT AND BALANCED REPORT ON THE LINE 5 ALTERNATIVES. DESPITE THE CLEAR LANGUAGE OF STATE’S RFP, DYNAMIC ELECTED NOT TO DO A THOROUGH STUDY OF EITHER ALTERNATIVE 2 (USING THE EXISTING PIPELINE INFRASTRUCTURE AND ALTERNATIVE 1 (CONSTRUCTING A NORTHERN ROUTE PIPELINE THROUGH ONTARIO). DESPITE HAVING THIS CLEAR CONTRACTUAL VIOLATION BROUGHT TO THEIR ATTENTION, DYNAMIC STILL HAS REFUSED TO COMPLETE ITS AGREED-UPON ASSIGNMENT.



    I ALSO URGE YOU AND EACH MEMBER OF THE PSAB TO CAREFULLY REVIEW DR. ED TIMM’S RECENTLY (12/11/17) RELEASED FINAL TECHNICAL PAPER ON THE BIAS AND ERRORS IN DYNAMIC RISK’S WORK HERE. WHILE THIS IS PRIMARILY AN ENGINEERING DEBATE, EVEN NON-ENGINEERS CAN SEE THE PROBLEMS OUTLINED BY DR. TIMM. I SUBMIT TIMM’S PAPER PROVES THE POINT THAT THE STATE MADE A GRAVE ERROR IN ASKING AN OIL INDUSTRY SUBCONTRACTOR TO DO AN INDEPENDENT ANALYSIS. DYNAMIC RISK WILL NOT RESPOND TO TIMM UNLESS YOU MAKE THEM. MAKE THEM! BETTER YET, ASK THE MEADOWS RISK STUDY GROUP TO DO A PEER REVIEW OF THE FINAL REPORT AND DR. ED TIMM’S RESPONSE.
    ONE EXAMPLE THAT THE TIMM REBUTTAL HIGHLIGHTS IS THE DAMAGE DONE TO THE TWIN PIPELINES FROM 1953 TO 2003 AS REVEALED IN THE KIEFNER REPORT. WE KNOW THAT IN 2003, INSPECTIONS SHOWED 16 UNSUPPORTED SPANS GREATER THAN 14O FEET, INCLUDING ONE AT ALMOST 300 FEET. THESE EASEMENT SPAN VIOLATIONS SHOW THE FUNDAMENTAL DESIGN ERROR IN PLACING THE PIPELINE ON THE BOTTOM OF THE STRAITS WITH AN ERRONEOUS ASSUMPTION ON THE POTENTIAL IMPACT OF HIGH CURRENTS. BOTH DYNAMIC RISK REPORTS CHOSE TO PASS ON THE DAMAGE ATTRIBUTABLE TO THESE EASEMENT VIOLATIONSCLAIMING THAT ONE INLINE INSPECTION IN 2014 SHOULD QUIET ANY CONCERNS. DYNAMIC RISK SHOULD BE EMBARRASSED TO ARGUE THAT A TEST FOR CRACKS WOULD HAVE DISCLOSED OTHER STRUCTURAL PROBLEMS ATTRIBUTABLE TO 50 YEARS OF NEGLECT.
    THIS RESULT- ORIENTED CONCLUSION SHOWS A DEGREE OF BIAS AND FLAWED ANALYSIS THAT DEFIES COMMON SENSEAND IS ALL TOO TYPICAL OF THIS REPORT. DR. TIMM’S RESPONSE TO THE 2014 ILI TEST WHITEWASH (PAGES 16-20) IS SIMPLY DEVASTATING TO DYNAMIC RISK’S ALLEGED EXPERTISE. MORE IMPORTANTLY, IT IS YET ANOTHER WARNING SIREN TO ANYONE TRULY INTERESTED IN KEEPING OIL OUT OF THE GREAT LAKES.


    THE CRITICISM RAISED BY DR. TIMM PAPER SHOULD NOT BE FILED AWAY LIKE THE PSAB’S 2018 REPORT. THE WORST THING THAT THE PSAB CAN DO IS TO ACCEPT AN INCOMPLETE AND TECHNICALLY FLAWED FINAL REPORT FROM DYNAMIC RISK. IT’S BAD ENOUGH KNOWING THE PSAB’S EFFORTS MAY BE IGNORED. DON’T MAKE THE SITUATION WORSE BY LEAVING A TERRIBLY FLAWED FINAL REPORT AS THE PSAB’S ONLY LEGACY.




    LEONARD PAGE

    9482 PAGE ROAD

    CHEBOYGAN, MI 49721

    age
  • signed 2017-12-12 13:59:14 -0500
    It is imperative to SHUT DOWN LINE 5. Common sense, scientific findings, studies of the pipeline, how damaged/old it is, how vulnerable our Great Lakes and connecting waterways are should there be ANY spill. This will be devastating to our fresh water supply, our economy, our tourism, many folks earning a living. IT IS THE RIGHT THING TO DO: Shut it down, NOW. Before it is too late and we will all suffer and be sorry. Waiting for ANOTHER FLINT WATER CRISIS? That one is unforgiveable for everyone involved.

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