The Line 5 tunnel isn’t what we were told.

Published on August 12th, 2025 by - Blog Posts

Line 5 – the 72-year-old dual pipelines suspended across the bottomlands of the Straits of Mackinac – has been battered by anchor strikes and entangled by cables from passing ships. It is universally accepted that the exposed pipelines represent a clear and present danger to the Great Lakes and the regional economy should Line 5 fail.

In the final two months of Governor Rick Snyder’s second term in 2018, the State of Michigan hurriedly signed four agreements with Enbridge, the Canadian pipeline company that owns and operates Line 5, authorizing the construction of a tunnel beneath the Straits of Mackinac intended to contain and protect Line 5.

The agreements, hastily prepared without public hearings or public review of any kind, require the State of Michigan to take ownership of the tunnel once construction is complete, and to oversee the operation and maintenance of the tunnel for the next 99 years.

There is one notable  problem with this unusual partnership between the State and Enbridge: The tunnel the State agreed to manage is not the tunnel that Enbridge intends to build. 

"Almost every aspect of the tunnel’s design, construction, and operation is radically different that what was originally intended," says Brian O’Mara, an expert with over 30 years of tunnel construction experience. "The tunnel project is so off track in so many ways, it is questionable that it can ever be successfully constructed, let alone operated safely."

Basic design assumptions for the proposed tunnel.

The State’s participation in the tunnel project was based on a detailed report, Alternatives Analysis for the Straits Pipeline, authored in 2017 by Dynamic Risk Assessment Systems, Inc., a company providing engineering consulting services to the pipeline industry. Dynamic Risk’s assessment was based upon a tunnel design that was distinctly different from the tunnel design that Enbridge proposes today.

Dynamic Risk recommended a tunnel alternative for Line 5 pipeline based upon the following assumptions:

  1. A thorough and comprehensive investigation of the lakebed would be conducted to understand the geological conditions that the proposed tunnel project would encounter.
  2. The pipeline within the proposed tunnel would be permanently embedded in concrete that would completely fill the 10-foot diameter of the tunnel.
  3. The tunnel would be bored through entirely sound and solid bedrock.
  4. There would be minimal groundwater inflow and pressure.
  5. There would be no methane or toxic gas (H2S) encountered.

None of these assumptions proved to be true or accurate.

How the tunnel has changed.

First, the Dynamic Risk evaluation assumed that “a comprehensive site-specific subsurface investigation and lab testing program would be required” by the State of Michigan, before construction to identify the characteristics of the rocks the tunnel excavation would encounter.

But the expert consultants, McMillen Jacobs Associates (MJA), retained by the Michigan Department of Transportation, identified numerous problems and red flags that were not adequately addressed in Enbridge’s investigation of the proposed tunnel path. For example, MJA found that Enbridge “did not adequately characterize the anticipated ground conditions on site” and that many of the rock sample borings intended to characterize the underlying geology did not reach the proposed depth of the tunnel, with only one boring sample taken from the most critical two-mile length of the tunnel’s proposed pathway.

Second, the tunnel design recommended and approved by the State’s consultant, Dynamic Risk, was a tunnel, 10 feet in diameter, with a “closed annulus,” meaning that the interior of the tunnel would be filled with an impermeable, inflammable cement surrounding the pipelines. The concrete would permanently seal the pipelines, preventing damage or leaks and affording an additional critical measure of safety. The present design is for an open, unsealed, 21-foot tunnel lacking the security and protection that a sealed tunnel would provide.

Third, the Dynamic Risk report on which the State relied assumed that the tunnel would be bored through solid bedrock. But Enbridge’s limited investigation found conditions that would be extremely challenging. It found that the tunnel route would encounter rock formations that are highly fractured and highly permeable, with most rock formations classified as “poor” or “very poor.” Moreover, the boring samples repeatedly encountered “voids”- open underground spaces that would need to be filled with concrete and grout before the tunnel boring machine could progress through the proposed route.

Fourth, the MJA consultants found that the extreme depth of the tunnel route will result in the boring effort encountering high “hydraulic conductivity and hydrostatic pressure” constituting “areas of significant risk impacting tunnel operations due to high groundwater inflows.” The MJA reports state that pressures may “overwhelm” the systems designed to treat water infiltration, estimated at 25,000 gallons per day. The US Army Corps of Engineers’ draft Environmental Impact Statement indicates that the pressures the tunneling machine would encounter may be the highest ever in a tunnel construction project.

Fifth, Enbridge reported that no methane of consequence was encountered in its limited geological investigation, but internal reports indicated that methane was detected in some of the samples and Enbridge failed to note that the proposed tunnel would be situated directly above the Collingwood-Utica Shale Oil and Gas play capable of yielding gas and oil in recoverable quantities. In 1971, a similar tunnel building effort in Lake Huron resulted in a methane explosion that killed 22 construction workers inside the tunnel.

A continued threat to the Great Lakes.

The tunnel project on the table today is substantially different from the tunnel project that was proposed when the agreements were signed by Governor Snyder. And the tunnel design recommended by Dynamic Risk and relied upon by the Michigan Public Service Commission (MPSC) and the Mackinac Straits Corridor Authority (MSCA) is not the design being advanced by Enbridge now. 

The proposed tunnel construction has the potential to impair both the Great Lakes bottomlands and the waters of Lakes Michigan and Huron.  A recent survey found that there have been 321 documented tunnel failures through 2020.  The proposed project is replete with “red flags” indicating the project will encounter extraordinary environmental challenges. It is clear that the proposed tunnel project is not as safe as Enbridge wants Michiganders to believe. The risks that the proposed project presents to the Great Lakes cannot be ignored. With the permitting process for the tunnel underway, we must all call on our federal and state agencies to protect the public interest in our shared freshwater resources.

Silent auction to fight Osceola County potash and salt mine

Published on August 11th, 2025 by - Blog Posts

Right now, Flow Water Advocates is fighting to stop a proposed potash and salt mine in rural Osceola County that threatens some of Michigan’s most fragile and pristine wetlands. 

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If built, the mine would withdraw over two million gallons of freshwater every day, and inject chemical waste deep underground—posing serious risks to drinking water, wildlife habitat, and public health.

Even more troubling? The company behind the project has no production track record, and is asking the public to foot the bill. With a billion-dollar federal loan request pending, we have a short window to raise awareness, build public pressure, and pursue action that could help stop this destructive project in its tracks.

That’s where you come in. Our goal is to raise $7,500 through this silent auction to support our legal, policy, and advocacy work to protect Michigan’s water and wetlands. Every bid you place helps us take action at this critical moment.

Just a few of the terrific items you can bid on today:

The International Joint Commission is seeking public input on its draft 2025 report.

Published on August 11th, 2025 by - Blog Posts

The International Joint Commission (IJC) is seeking public comment on the recently released Draft 2025 Review of the International Joint Commission’s Report on the “Protection of the Waters of the Great Lakes”. The report updates the IJC’s analysis of Great Lakes stresses from consumption, diversion, and removal of water from the Great Lakes.

The IJC issued its first report with recommendations on the Protection of the Waters of the Great Lakes in 2000, following a formal request, or “reference” from the governments of Canada and the U.S.

A three-year review was released in 2004, and a 10-year review in 2015. The analysis in the draft 2025 report is informed by interviews with over 30 key stakeholders and subject-matter experts.
This draft report provides a preliminary evaluation of the relevance and implementation status of recommendations issued by the IJC in a 2015 report. It also proposes new recommendations for the IJC to submit to governments. Among the recommendations:

  • Before further pursuing AI and data center projects for siting within their boundaries, the states and provinces should consult with experts how these growing water uses impact the Great Lakes basin.
  • The Great Lakes states and provinces should convene a panel of legal experts to ascertain the significance and potential of the public trust doctrine to assist in protection of the waters of the Great Lakes while allowing for a public comment period.
  • The Great Lakes states and provinces should increase collaboration with Indigenous Nations in decision making on major water withdrawals and diversions.

A public webinar will be held on August 14 from 12pm-1pm (EDT) to provide an overview of the preliminary findings of the draft report and record public comments. Comments can also be provided in writing to the IJC.

The comment period is open until August 31, 2025.

Register for the webinar
Access the report

Flow Water Advocates welcomes 3 new board members.

Published on August 11th, 2025 by - Blog Posts

Flow is thrilled to welcome three incredible new members to our Board of Directors: Environmental journalist Keith Schneider, MSU Assistant Professor Kelly Hirko, and MSU Assistant Professor Anthony Kendall!

Each brings a deep commitment to protecting the Great Lakes, along with unique expertise—from community organizing and environmental law to science, education, and advocacy. Together, they will help guide our mission to safeguard our waters, wetlands, and the communities that depend on them.

We’re grateful for their leadership, passion, and vision—and excited for the waves we’ll make together. Please join us in giving them a warm welcome!

Meet Keith Schneider.

Keith Schneider is a nationally prominent environmental journalist and editor who reports on the intersection of energy, agriculture, and water from across the United States and around the world. A former national correspondent and regular contributor to the New York Times, Keith also reports for The Guardian, ProPublica, National Geographic, Energy News Network, Mongabay, The New Lede, and Circle of Blue. 

Read more about Keith

Meet Kelly Hirko.

Kelly Hirko is an Assistant Professor in the Department of Epidemiology and Biostatistics at Michigan State University’s College of Human Medicine, and a community-based researcher at Michigan State’s rural medical campus in Traverse City. Her research seeks to elucidate the role of modifiable lifestyle, environmental and social determinants on cancer prevention, control, and disparities.

Read more about Kelly

Meet Anthony Kendall

Anthony Kendall is an Assistant Professor jointly appointed in the Earth and Environmental Sciences Department and AgBioResearch at Michigan State University. He is a lifelong resident of Michigan, at the heart of the Great Lakes. Anthony studies how climate and land use affect water resources, and the human and ecological systems that rely on those resources.

Read more about Anthony

Have a water story? Flow is looking for live storytellers!

Published on August 6th, 2025 by - Blog Posts

Calling all storytellers and water lovers!

On February 5, 2026, 7pm, Flow Water Advocates is teaming up with Here:Say Storytelling to present a night of true, first-person stories about water – from ice hockey, to fishing, to why you love boating with your grandma. The Great Lakes are more than just a natural wonder — they shape who we are. They hold our memories, fuel our creativity, sustain our communities, and inspire awe, generation after generation. We Are Made From Rivers brings together local storytellers to share powerful testimony to the waters that made us.

Pitch your story

Save the Date:
Who: Flow Water Advocates & Here:Say Storytelling & Beth Price Photography
What: We Are Made From Rivers, a local true, first-person storytelling event
When: February 5, 2026 at 7pm
Where: Kirkbride Hall, Traverse City

We’re looking for 5 to 6 storytellers to share their experiences at Kirbride Hall at 7pm on February 5. The event will also feature the photography of Beth Price, an outstanding editorial and commercial photographer based in Northern Michigan.

Each performer will participate in Here:Say Storytelling’s workshopping process. This is required to ensure a congruence between each story. The workshopping process will take place between November and January and prepare each story and storyteller for the performance. 

To pitch your story idea: 

  • Submit your story idea via the Google Form in a 1 paragraph pitch. Tell the quick abbreviated version of your story. Submit your pitch by September 30, 2025.
  • Stories will be selected and storytellers will be notified by October 17, 2025. 
  • The workshopping process with Kabie Stein and Here:Say Storytelling and will begin after selection.
  • Contact Marshall at Marshall@FlowForWater.org for more questions.
Pitch your story

Frequently asked questions:

What’s the Here:Say vibe?

To listen to past shows to get to know the Here:Say vibe and a sense of the storytelling model we follow, listen to the podcast.

No experience necessary. All that’s required is an openness to engaging in the story workshopping process and a willingness to tell your story on stage to an audience.

Here:Say stories are true, first-person narratives that tell the story of a specific experience the teller had within their lives.  There’s no requirement about tone (it doesn’t have to be a funny story), but it should be meaningful to you in some way and make for an entertaining story.

You can say of your story, “This is an experience that happened to me.”

There are many perfectly legitimate forms of storytelling, but some are meant to be read rather than listened to aloud. But we don’t necessarily give an automatic “no” to the stories that we think just don’t work on stage – instead, if you are game for it, we will workshop the story with you to find a way to tell it in a way that aligns with the Here:Say model.

Memoir that covers a whole lot of timeline, “journey” stories that evaluate an experience instead of telling what happened, long anecdotes that only serve to get to a punchline, other people’s stories, rants and comedy riffs on an overall topic, fiction, stories that comment on the process of telling a story.

Stories are about 10 minutes in length, which translates to approximately 5 double-spaced pages in Word.

The process will begin the first week of November and will conclude the end of January to ensure enough time to practice before the show. An extra 30 days was added to accomodate the holidays toward the end of the year. The process is outlined below: 

  • Submit the 1 paragraph pitch at the link above via the Google Form.
  • If selected, you will be introduced to Kabie Stein via email by Flow Water Advocates.
  • Write your story, then submit a draft via email to Kabie. (Word preferred.)
  • Kabie reads the story and returns the draft to you with feedback. Typically this feedback is provided as comments/questions in the document itself and an overall response in the email.
  • Submit revised draft to Kabie Stein.
  • Repeat steps 3 and 4 as needed, until you and Kabie both feel it’s ready for stage.
  • Perform your story live on February 5, 2026. 

Nitrates in well water: What you need to know and what you can do.

Published on August 1st, 2025 by - Blog Posts, Reports & Media Releases

What are nitrates and why do they matter?

If your household water comes from a private well, you may be at risk of nitrate contamination —and not even know it. Nitrates are a type of nitrogen compound that can seep into groundwater from the use of fertilizers, manure, and failing septic systems. The problem? Nitrates are colorless, odorless, and tasteless — you can’t detect them without testing. At high enough levels, they can harm your health. Long-term exposure to even moderate nitrate levels has been linked to increased risks of thyroid, colorectal, ovarian, and bladder cancers and adverse pregnancy outcomes, including preterm birth and birth defects. People with compromised immune systems or chronic illnesses may also face higher risks.

Download our policy brief: Nitrates in well water: What you need to know

This worksheet breaks down nitrate pollutionto better understand the impacts that nitrates inflict on the environment, the animals, and the threat to public health in communities across Michigan.

Download here

Policy Brief: The hidden costs of anaerobic digesters and biogas

Published on July 31st, 2025 by - Blog Posts, CAFO, Reports, Reports & Media Releases

Anaerobic digesters are facilities that decompose organic waste, separating biogas from a sludge called “digestate.” Biogas can be used on-site, paired with a facility like a livestock confinement, or processed into purified pipeline-grade biomethane for electricity or transportation. While biogas can be part of a sustainable farm operation, it has many potential shortfalls that must be evaluated carefully to protect the public interest.

On concentrated animal feeding operations (CAFOs), a digester may be a cover on a cesspit. After the methane is captured, CAFO operators spread untreated digestate — which may contain biological hazards like thermotolerant, antibiotic-resistant E. coli bacteria — onto farm fields as “fertilizer.” Digesters fed by sources like municipal food waste may produce digestate that is contaminated by high levels of heavy metals and toxic compounds like PFAS and PFOS, which may then be sold or given away to spread on fields.

Download the PDF below to learn more! 

Download our policy brief: The hidden costs of anaerobic digesters and biogas

This worksheet breaks down anaerobic digestion to better understand the impacts that CAFOs inflict on the environment, the animals, and the threat to public health in communities across Michigan.

Download here

Explore more about CAFOs

Advisories against consuming fish triple in Michigan

Published on July 29th, 2025 by - Blog Posts

A science review has prompted state officials to sharply increase the number and scope of fish consumption advisories related to perfluorooctane sulfonate (PFOS), a chemical that is part of the dangerous PFAS family of “forever chemicals.”  The advisories encourage Michiganders to limit, or in some cases stop, eating some species of fish, depending on the river or lake affected.

Last year, the state issued “do not eat” advisories due to PFOS, for at least one species on 33 lakes and streams. This year, there are “do not eat” advisories on 98 lakes and streams.

The updated guidelines lower Michigan’s “do not eat” level for PFOS from 300 parts per billion (ppb) to 50 ppb, based on growing evidence about the health risks associated with PFAS. 

The Michigan Department of Health and Human Services (MDHHS) made the announcement in June while releasing its annual Eat Safe Fish guide.

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A scientific review of PFOS provided MDHHS more information about the toxicity of PFOS and its impact on human health, the department said. “PFOS has been found to be a greater threat to human health than previously thought and has resulted in changes to this year’s Eat Safe Fish Guides,” the department said. “Additional guidelines are included due to PFOS for both entire waterbodies and specific fish species, including an increase in the number of Do Not Eat guidelines.”

The state last reviewed PFAS science in 2014 to determine fish consumption advisories. The recent review resulted in a six-fold reduction in the fish contaminant levels at which “do not eat” is recommended.

“This news shows the urgency of toughening our laws and policies to stop the next chemical disaster. It’s important not to repeat the mistakes that let PFAS chemicals into our food and drinking water in the first place,” said Liz Kirkwood, Flow Water Advocates Executive Director. 

 

“This new advisory is a major win for public health and a long-overdue acknowledgment of the science on PFAS,” said Tony Spaniola, co-chair of the citizen coalition, the Great Lakes PFAS Action Network. “These new guidelines will help protect people across Michigan – especially in frontline communities that rely on fish as a food source. I urge MDHHS and local health departments to get the word out to impacted communities without delay.”

Epidemiological evidence suggests links between increases in exposure to PFOS and:

  • Increases in cholesterol levels;
  • Lower antibody response to some vaccines;
  • Changes in liver enzymes;
  • Pregnancy-induced hypertension and preeclampsia;
  • Small decreases in birth weight.

PFAS are human-made chemicals used in industry and consumer products worldwide since the 1940s. PFOS has been used in fire-fighting foams and fabric protectors and stain repellents, such as Scotchguard. PFAS are found globally in the blood of people and animals and in a variety of food products and in the environment. A U.S. EPA study found PFOS in every fish analyzed. Because they do not break down in the environment, they are known as “forever chemicals.”

FAQs: Making public comments to EGLE on the Line 5 tunnel

Published on July 28th, 2025 by - Blog Posts

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) is taking public comments on Enbridge’s proposed Line 5 pipeline tunnel through August 29, 2025. The State of Michigan now has the power to deny the tunnel permit, and protect the Great Lakes from years of construction upheaval, wetlands damage, and other risks. 

Submit your comments to EGLE
What every Michigander should know about the Line 5 tunnel

Michigan can assert its sovereignty, stop the exploitation of our publicly-held resources for private profit, and protect the waters today, and for future generations. Here’s how you can engage with EGLE on this important issue: 

(1) Attending a virtual public information session on August 12 (6:00pm EDT). This is an opportunity to ask EGLE representatives questions and learn more about the application and next steps.

(2) Attending the virtual public hearing on August 19 (6:00pm EDT) and providing oral comments that will be considered by EGLE in its review of the application .

(3) Submitting written comments that will be considered by EGLE in its review of the application by August 29.

Here are answers to some of the questions we’ve received about the EGLE permit process, and how to get involved:

If I have already submitted comments on the project, can I submit comments during this public comment period?

Yes. The current application for a Water Resources Permit under Michigan’s Wetland Protection Act (Part 303) and Michigan’s Great Lakes Submerged Lands Act (Part 325) is distinct from the review of earlier permit applications for the project, so it is important to submit comments on the current proposal to ensure your voice is heard.

Flow Water Advocates will be providing both oral comments at the August 19 hearing and written comments by the August 29 deadline, and we encourage interested members of the public to do the same.

Do I have to live in Michigan to contribute comments?

No, we all have an interest in protecting the Great Lakes and there are no restrictions on who can participate in the public comment period.

What makes a strong public comment?

The most effective comments are grounded in the facts of the proposed project and its likely impacts, and the requirements for permit approval under the law. Highlighting your personal connections to the waters, ecosystems, communities, cultural resources, and economies that stand to be impacted by the project is also powerful.

When preparing to provide oral comments at the public hearing, we recommend that you write down what you would like to say in advance and practice sharing it a couple times, as each person is usually allowed only 3 minutes to speak. Three minutes of speaking time is about 400 words, depending on how quickly you speak.

What are some of Flow Water Advocates’ major concerns with Enbridge’s permit application?

First, Enbridge has not provided sufficient information–on the full project, its potential environmental impacts, or the available alternatives–for EGLE to properly consider its application for a Water Resources Permit under Part 325 and Part 303 of Michigan’s Natural Resources and Environmental Protection Act .

Second, when all of the necessary information is considered, it is clear that the tunnel project cannot be lawfully permitted because the project will have more than minimal environmental effects, and because the shutdown of Line 5 is a viable, and much preferable, alternative to constructing an unprecedented tunnel project to house a new section of oil pipeline through the heart of the Great Lakes.

Finally, Enbridge does not have the necessary legal authorization to operate the proposed tunnel project in the Straits, as required under the Great Lakes Submerged Lands Act and Michigan’s public trust doctrine.

For more information on the potential environmental impacts of the project, deficiencies with the application materials, and the viable alternatives that must be considered, visit our website: https://flowwateradvocates.org/line5/.

If we don’t have time to comment on everything, are there any aspects of the permit that we should prioritize?

There is certainly a lot to cover–the gaps in the application, the many potential environmental impacts, and the available alternatives to the project that must be considered.

When you have limited time to prepare comments, a good strategy can be to focus your comments on an issue or two that you care about or in which you have particular insight or expertise, knowing that others will do the same.

Oil and Water Don’t Mix has compiled a list of several issues that can be raised and expanded on in public comments.

Earthjustice has also provided a helpful comment submission form with a message to get you started.

If you have additional questions about submitting comments, we encourage you to attend the public information session hosted by EGLE on August 12.

When you register for the session, there is the option to include questions that you would like to be addressed by the agency and there will also be time for additional questions at the end of the session.

Factory farm webinar: Weigh in on how Michigan regulates factory farm waste.

Published on July 21st, 2025 by - Blog Posts

Watch the recording

Factory farms, or Concentrated Animal Feeding Operations (CAFOs), threaten our waters with immense quantities of sewage, which too often are sprayed on fields where it can then runoff into streams and leach into groundwater — including into our drinking water. 

On August 8, the Michigan Department of Environment, Great Lakes, and Energy (EGLE ) will hold an hybrid remote public hearing in Lansing on the long-contested 2020 NPDES-CAFO General Permit, to regulate factory farm waste discharges to our waters. 

To prepare for this important hearing, join Flow Water Advocates on July 31 at Noon for a briefing on the issue, and learn how you can weigh in to support effective regulation and clean waters in rural Michigan and the Great Lakes. 

Flow has been an intervenor in an administrative contested case and litigation on this permit over the past 5 years. 

How to join the EGLE public hearing on August 8 at 9:00am:

Location: Microsoft Teams Meeting
Meeting ID: 293 614 609 636 1
Passcode: 6FV72vK3
Call in (audio only)
Telephone: 1-248-509-0316 (Toll)
Phone Conference ID: 581 485 136#