The report on alternatives to Line 5 in the Mackinac Straits:
·Fails to follow the recommendations and standardsoutlined in the Michigan Petroleum Pipeline Task Force Report and should be withdrawn.
·Neglects to provide the state with an independent, fair analysisof the alternatives to Line 5. This report is clearly biased toward allowing Line 5 to continue to operate and/or allowing Enbridge to build new oil infrastructure and further expand its operations.
·Ignores using existing pipeline infrastructureas an alternative to Line 5 in the Straits.
It is unacceptable that the contractor eliminated this alternative in the early stages of analysis, and this must be remedied in the final report.
·Does not provide a worst-case scenario spill and cost analysis,which was one of the main objectives of this report and was specifically required by the state.
·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.
Shows unfair bias towards building a tunneled pipeline. Dynamic Risk has a preference for 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.
Utilizes incomplete analysis, making it highly suspect and raising questions about the study’s credibility in evaluating thecondition of the 64-year-old Line 5—.
Ignores that records and data are publicly available proving that the pipeline was bent in multiple areas at least 26 years after the pipeline was installed.
Bases the probability of a pipeline rupture on average weather conditions rather than extreme conditions of high winds and waves. This decision to use meteorological data from a period where “Wind conditions are fairly average compared to other years, without any particular high wind events or extreme situations” defies common sense.
The magnitude of the risk of a spill is too severe to allow Line 5 to continue to operatein the Great Lakes. Michigan 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.
I urge you to act as legal public trustees of our waters and bottomlands, enforce the ongoing easement 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 an independent legal duty to take this enforcement action based on Enbridge’s ongoing violations.
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.