The Superior Rivers Watershed Association has submitted a written comment to the Wisconsin Department of Natural Resources in lieu of oral comments for the public hearing on the proposed reroute of Enbridge’s Line 5 pipeline in Ashland, Bayfield, and Iron Counties. The hearing will be held virtually at 4pm on Wednesday, July 1, 2020.  Written comments may be submitted no later than July 11, 2020. For information on the July 1st hearing or written comments, please visit: https://dnr.wi.gov/topic/EIA/Enbridge.html We urge you to submit your written comment by July 11th.   Our comment:   To the Wisconsin Department of Natural Resources: The Superior Rivers Watershed Association writes to urge the Department of Natural Resources not to grant permits for Enbridge to create a new section of Line 5 in Wisconsin. Superior Rivers Watershed Association is a non-profit organization based in Ashland, Wisconsin whose mission is to promote the healthy connection between the people and natural communities of our watersheds by involving all citizens in assessing, maintaining and improving watershed integrity for future generations. The proposed pipeline corridor will be developed within the Bad River watershed, which is characterized by numerous high quality water resource streams, wetlands, sloughs, and more. The proposed corridor will cross State of Wisconsin Department of Natural Resources-designated Exceptional or Outstanding Resource Water stream segments nine times, and will cross US-Fish and Wildlife Service-designated critical brook trout fishery stream segments five times. Because of these and numerous other ecological and community safety issues, the Superior Rivers Watershed Association’s position is that transportation of hazardous materials, including pipelines carrying oil, gas, and other toxic fluids, should avoid crossing Lake Superior’s watersheds. When that is not possible, all precautions should be taken to minimize the potential for harm to water quality. Of concern to the Superior Rivers Watershed Association is that the proposed reroute will increase, not minimize, the potential for water quality degradation by increasing the number of streams and wetlands it will cross. Aside from the potentially devastating localized effects of pipeline leaks or spills, other impacts of the proposed reroute concern us:

• Removal of shading vegetation cover at pipeline stream crossings. Multi-year  water temperature data collection at 14 sites in the proposed corridor demonstrate presence of exceptional cold water resources. Cold water temperatures are at least partially maintained by shading from abundant streamside vegetation.
• Construction of crossing sites and maintenance access roads. Erosion and sedimentation severely impair many streams in the watershed. Parts of the pipeline corridor lie within areas prioritized by regional interagency working groups for reduction of erosion and sedimentation potential. Additionally, the entire corridor footprint lies in documented range of the wood turtle, a Wisconsin DNR-listed threatened species. Twenty-one potential nesting habitat sites may experience short term to permanent negative  impacts from construction disturbances.
• Pipeline exposure and destabilization. The Bad River watershed is an historically flood-prone region, and has been subjected to three record-breaking flooding events since 2012. These events have resulted in loss of life, property, and infrastructure, twice on a catastrophic scale. Multiple regional climate models forecast increasing frequency of large precipitation events.

All of these potential impacts can affect our region’s clean water resources in numerous and unknown ways, yet none of these impacts are well-understood in terms of their possible extent or how effectively they could be responded to. In addition, extensive wetlands critical to the water and cultural resources of the Bad River Band of Lake Superior Chippewa Indians all lie directly downstream of the proposed pipeline reroute, including the Kakagon/Bad River Sloughs ecosystem, which was designated a Wetland of International Importance by the United Nations Ramsar Convention in 2012. This globally unique ecosystem:

• Supports wild rice;
• Supports diverse Lake Superior and inland fisheries;
• Controls flooding; and
• Filters pollutants from water.

With so much at stake, this is not a decision which can be made without being fully informed. The Department of Natural Resources should therefore not grant permits for Enbridge to create a new section of Line 5 in Wisconsin before it completes its Environmental Impact Statement. Here are our thoughts about what the scope of the Department of Natural Resources’ Environmental Impact Statement investigation should be:

• Include at least the following issues: impacts to wetlands, streams, rivers, the Kakagon Sloughs, the Bad River, Copper Falls State Park, and Lake Superior;
• Investigate the potential harms of blasting through granite and the faults that can open up or shut down because of it, and the potential for well contamination due to faults plus a spill;
• Investigate how construction through wetlands and streams, resulting in erosion, gullies, and silt deposits downstream, impact aquatic species and exacerbate flooding in the region;
• Investigate how wildlife habitat would be impacted. Creating new, long-term openings to habitat can break up habitat blocks and bring invasive species; and
• Consider Enbridge’s broader safety record outside of Line 5.

The Superior Rivers Watershed Association recommends that the Department of Natural Resources should not decide on any permits before it completes its Environmental Impact Statement, which should include the full scope of the impact of all watersheds linked to the proposed Line 5 reroute and Lake Superior. Only this full scope Environmental Impact Statement should guide the Department of Natural Resource’s decisions.