Tag: FLOW

LivingstonDaily.com: ‘Fracking’ authority debate ignites

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‘Fracking’ authority debate ignites

By Christopher Behnan

February 9, 2014

FOWLERVILLE, MI – Fighting big oil would be a costly proposition for any local government.

That doesn’t mean local officials don’t have legal ground to challenge drilling operations, including those that use hydraulic fracturing to maximize oil and gas extraction from rock formations, environmental officials said last week.

That’s particularly the case when drilling that uses high-volume “fracking” transports hazardous materials on public roads, disrupts peaceful communities or draws millions of gallons of water from local water supplies, they added.

The ability of local governments to regulate drilling operations has been front and center since Texas-based GeoSouthern Energy Corp. received a state drilling permit allowing injection of 3 million gallons of water, sand and chemicals on private property in Conway Township.

Environmental groups, including Traverse City-based For Love of Water, the state Department of Environmental Quality and the oil and gas industry often have different views on the local-rule issue.

Each is armed with voluminous case law they claim supports its views.

Last week, FLOW gave Conway Township and other local officials an overview of hydraulic fracturing in Michigan and discussed local ordinances it said empower local governments.

FLOW Chairman Jim Olson said local governments have a host of regulatory powers over drilling sites, including under Michigan’s Zoning Enabling Act and state law that favors public health and safety over commercial interests.

State law doesn’t allow local governments to regulate the location of drilling projects or prohibit drilling practices, including hydraulic fracturing, but does allow regulation of noise, air pollution, use of hazardous substances, Olson said.

“You can actually pass ordinances and regulate pretty much any activity that causes interference with the use and enjoyment of property of the community lands and parks and schools,” Olson said.

Because the zoning act only prohibits regulation of drilling wells, local governments also can regulate several “ancillary activities” such as related storage, chemical mixing, pumping activities and truck traffic, Olson added. He said local officials can require site plans from oil and gas companies for their projects.

He said local governments can require drilling permit applicants to submit environmental impact statements to local units under Michigan’s Environmental Protection Act.

Current law doesn’t require oil or gas companies to disclose chemicals used in the fracking process, but officials can require disclosure of chemicals transported on local roads, he added.

“You can say, ‘Well, here’s our roads. You’re going to have to tell us what you’re hauling on these roads and what you’re disposing,” while using the roads, Olson said.

DEQ oversight of operations

Exclusion of drilling oversight in the zoning act leaves jurisdiction over drilling and related operations such as fracking in the hands of the director of the state Department of Environmental Quality, said Adam Wygant, section chief with the DEQ’s Office of Oil, Gas and Minerals.

Wygant on Wednesday will discuss oil and gas operations with Livingston County officials.

Local governments have a say when oil and gas companies want to establish ancillary operations, such as treatment or equipment-storage facilities separate from drilling sites, however, he added.

Local officials can pass bans and moratoriums, but they will not be enforced under current law because the DEQ director, as Michigan’s supervisor of wells, has exclusive oversight of drilling operations, Wygant said.

“We believe our authority is what it is and what has been upheld by case law,” he said.

FLOW’s Olson said it’s possible, but unlikely, for local officials to impose a ban or moratorium on drilling or fracking. That’s in large part because private landowners have the right to lease their lands as they see fit, Olson said.

He said townships would have to prove there is no way to allow hydraulic fracturing anywhere within its boundaries without harming the health and safety of residents.

“You would have to prove that in court, so it’s a pretty tough burden,” Olson said.

FLOW recommended that Conway Township consider drafting several ordinances, including requiring notification of drilling permits to the public and Board of Trustees before drilling begins; requiring companies to pay for water testing for residents within 2 miles of drilling sites before work begins; and requiring a road bond for possible repairs on company truck routes.

The DEQ in October announced proposed rules based on residents’ concerns about hydraulic fracturing, including installation of monitor wells and water sampling in certain conditions; notification to the state if hydraulic fracturing is expected to be used; and disclosure of chemical properties and concentrations used.

Environmental groups were not satisfied with the DEQ’s proposal.

Contact Daily Press & Argus reporter Christopher Behnan at 517-548-7108 or at cbehnan@gannett.com. Follow him @LCLansingGuy on Twitter.

Enbridge Under the Bridge: What We Do and Don’t Know about the Underwater Oil Pipeline in the Great Lakes

FLOW Executive Director Liz Kirkwood

FLOW Executive Director Liz Kirkwood

FLOW and a number of organizations have come together over the last year to rally the public and raise awareness about the Canadian energy company Enbridge and their Line 5 pipeline, a 61-year-old pipeline under the Straits of Mackinac in the Great Lakes which has increased in flow and pipeline pressure and poses a great risk to our common water. On February 5, I carpooled up to St. Ignace, Michigan to attend a public meeting wherein Enbridge delivered a presentation to Mackinac County officials (and a packed room full of concerned citizens) to assuage growing concerns about the Line 5 pipeline expansion. My companions Jim Dulzo from Michigan Land Use Institute, FLOW intern Jonathan Aylward and I didn’t know what to expect, but we certainly all had a lot of questions that remained unanswered.

Background: The issue captured our attention after a critical 2012 report from National Wildlife Federation (NWF) titled Sunken Hazardpublished the scary facts: if Line 5 were to leak, then in the eight minutes that it takes for Enbridge to shut off the pipeline about 1.5 million gallons of oil would release, along with catastrophic impacts and dispersion across both Lakes Michigan and Huron. However, this is not even the “worse case discharge” given that it took the same company, Enbridge, 17 hours to respond to the worse inland oil pipeline spill in U.S. history along the Kalamazoo River just 3 years ago.  In short, the Great Lakes have never been more at risk and yet the public is largely uninformed.

Why FLOW is concerned:

  1. We know that Enbridge has “upgraded” Line 5 with new pump stations but we don’t know for sure what “product” (light or heavy, sweet or sour, dilbit, etc) is being transported 640 miles from Superior, Wisconsin through the Straits of Mackinac to Sarnia, Ontario;
  2. Heavy tar sands is the dirtiest and most carbon-intensive energy on earth and a spill would destroy our shared international waters and way of life;
  3. This “upgraded” pipeline is 61-years-old and is submerged under water in the heart of the Great Lakes that contains 20 percent of the world’s fresh surface water;
  4. Enbridge has a dismal pipeline safety record, underscored by the two recent heavy tar sands disasters in Marshall, Michigan along the Kalamazoo River (1 million gallons spilled in 2010) and Grand Marsh, Wisconsin (50,000 gallons spilled in 2012);
  5. Federal pipeline regulations do not provide for public disclosure in the event of a product change from light crude oil to heavy crude oil for example; and
  6. An unsettling feeling of lack of transparency and public disclosure about the safety of Line 5 for the Great Lakes.

The Enbridge “side of the story”

At 2 pm at Little Bear Arena in St. Ignace, Mackinac County Planning Commission (“the Commission”) Chairman Dean Reid stood before 175 people, amazed at the turnout, and explained the rationale for this special meeting. The fact of the matter was that the Commission “wanted to hear Enbridge’s side of the story” after receiving NWF’s Sunken Hazard, and video footage of the submerged Line 5 under the Straits of Mackinac. Interestingly, though, I learned from Beth Wallace at NWF who co-authored the report that the Commission did not invite NWF to participate as a panelist to publically present both points of view.

Commission officials and the audience listen to the Enbridge representatives' presentation.

Commission officials and the audience listen to the Enbridge representatives’ presentation.

Chairman Reid laid out the agenda, calling for Enbridge to address the integrity of their Line 5 pipeline under the Straits of Mackinac, the frequency of their testing, and emergency procedures in the event of a pipeline rupture. Recognizing the potential regional impact a spill would have in the Straits, the Commission invited other local units of government and organizations to attend this meeting. No public comments were allowed, but Enbridge panelists read and answer cards with written questions.

Next came Enbridge Community Relations Director Jackie Guthrie who described herself as a mom but also as a former lieutenant colonel in the U.S. Army. She gave the audience a succinct and compelling PR presentation on Enbridge’s overall operations. “Think of Enbridge as the ‘Fed-Ex’ of the oil and gas industry,” she cleverly described, “Enbridge delivers 2.5 billion barrels of crude and liquid petroleum, 5 billion cubic/feet of natural gas, and 1,600 MW of renewable energy a day.” Her numbers underscored the amazing recent growth of this billion-dollar company coinciding with North America’s energy boom. For example, in the last seven years, Enbridge had doubled its employees to 11,000. Guthrie concluded her overview by noting that Enbridge was recognized as one of the Global 100 Most Sustainable Corporations in the World.

This last claim got me thinking: if Enbridge can get that level of praise despite its shocking track record of 800 pipeline spills in the U.S. and Canada between 1999 and 2010, leaking 6.8 million gallons of oil and causing the largest inland heavy tar sands rupture in U.S. history, I wonder what the other energy companies are like.

Guthrie described the Line 5 as a 650-mile pipeline originating in Superior, Wisconsin traveling across the Upper Peninsula across the Straits of Michigan and down to Sarnia, Ontario. Line 5 is a 30-inch pipeline, except across the Straits where it divides into two 20-inch pipelines. Guthrie emphasized that Line 5 was carrying “light crude oil” which has “the consistency of skim milk.”

The view driving across the Mackinac Bridge: the Enbridge Line 5 oil pipeline is submerged beneath the same Straits of Mackinac that the Bridge traverses.

The view driving across the Mackinac Bridge: the Enbridge Line 5 oil pipeline is submerged beneath the same Straits of Mackinac that the Bridge traverses.

Blake Olson, Enbridge’s Escanaba Area Manager for over 400 miles of Line 5, followed with a presentation on the integrity of the Line 5 pipeline. He described Line 5 in the Straits as a one-inch thick seamless steel pipe, build with such a robust design that they just don’t build pipelines like this anymore. In fact, Olson commented that Line 5 at the Straits is the thickest pipeline in North America. Since 2012, Enbridge had increased the flow or volume of the product by 10 percent. Then he made the case that Enbridge had made a number of significant upgrades in their leak detection system within the last couple of years, including:

  • automatic shut-off valves at both sides of the Straits,
  • replacement of St. Ignace Valve Yard (2011) and Valve Yard containment system (2012),
  • the on-going installation of emergence flow restriction devices,
  • a back-up electric generator installed in 2013, and
  • a thermally imaging leak detection system to be installed this year.

In addition, Olson described Enbridge’s integrity protective system along Line 5, which included corrosion prevention with coal tar coating and cathodic protection, anchor strike prevention and brackets every 50 feet (coming this summer), monitoring with internal and external pipeline inspections, lighted shore signage and nautical charts stating DO NOT ANCHOR.

Too little, too late?

This was an impressive list to the casual listener/observer, but what troubled me was that a lot of these basic safety protections to ensure pipeline protection were recently instituted and this pipeline was 61-years-old. For example, in the 61 years of this pipeline’s history, the U.S. Coast Guard did not have nautical charts informing vessels about the very location of Line 5 until January 2014.  This change only happened because a number of concerned Michigan groups met with the Governor’s office to discuss Line 5’s safety in December 2013.

Olson assured the audience that Enbridge’s integrity program demonstrated that Line 5 under the Straits was “fit for service” with no dents or anomalies and met all federal pipeline regulations.

Before the Q&A session, Enbridge invited its contractor Bill Hazel from Marine Pollution Control to provide an overview of the emergency response measures set in place in the event of catastrophic spill on Line 5 under the Lakes. Hazel pointed to a number of simulated winter emergency response drills that Enbridge had participated in or serves as the lead in 2008, 2012, 2013, and this year. What became crystal clear was how catastrophic a Line 5 rupture would be especially during the wintertime. One follow-up question captured our imagination of this seemingly impossible mission: ‘May day, May day, May day!  It’s January 21, 2014 and it’s -9 °F and the wind chill is -25 °F, the Straits of Mackinac are frozen over, the ice four feet deep, and Line 5 has ruptured under the ice.  What are you going to do about it?’

Left to right: Jim Dulzo, MLUI; Jonathan Aylward, FLOW; Lee Sprague, Little River Band of Ottawa Indians; Anne Zukowski, Don't Frack Michigan; Jannan Cornstalk, Little River Band of Ottawa Indians

Left to right: Jim Dulzo, MLUI; Jonathan Aylward, FLOW; Lee Sprague, Little River Band of Ottawa Indians; Anne Zukowski, Don’t Frack Michigan; Jannan Cornstalk, Little River Band of Ottawa Indians

Enbridge answers (some) public questions

Following a final word from the local emergency manager in Mackinac, Guthrie gathered the 5×7 questions cards, proceeded to sort them into piles, and distributed them to the appropriate Enbridge representative for answers at the podium. Several illuminating points came out:

  1. Line 5 only transports light crude oil, the consistency of skim milk.
  2. Line 5’s light crude oil currently comes the Bakken oil fields.
  3. There are no plans to pump heavy crude oil through Line 5.
  4. Seamless pipe wasn’t really a seamless pipe as Enbridge had described previously, rather Line 5’s two 20-inch pipelines are seamless only up to the joints that repeat every 40 feet along the 4-mile stretch along the bottomlands of the Straits.
  5. A wintertime spill would present unprecedented challenges in mounting an emergency response.
  6. If a rupture occurred and the automatic shut-off valves turned off in a 3-minute period, 5,500 barrels would be released and disperse over an area 25-square-miles wide.  This number was down considerably from 15,000 barrels before Enbridge installed the automatic shut-off valves.

The last question was: ‘If tar sands were being transported through Line 5, what pipeline changes would Enbridge have to make?’ Enbridge’s Guthrie pulled the card aside and said, “let me hold off on this question because it is complex.”  But time was on Guthrie’s side as the meeting ended sharply at 3:30 pm and she never had to answer this telling question.

The composed Midwestern temperament of the room quickly changed as audience members shouted out that their questions had not been answered.  But it was clear that the meeting was over.

The bottom line for the bottomlands

I walked out into the 12 °F air, looked out over the Straits and felt an urgent need for additional public forums in Mackinac and the Great Lakes to further educate and inform all walks of life who live here about Line 5. Enbridge had attempted to calm the public’s concerns about Line 5, but they hadn’t been entirely forthright and it bothered me. Without public transparency, we will need to engage the State of Michigan to assert its authority as trustee of the waters and bottomlands of the Great Lakes for the benefit of the public.

What I’m talking about is the public trust doctrine, which legally requires Governor Snyder and both the Department of Natural Resources and the Department of Environmental Quality, as state trustees, to ensure that Enbridge’s Line 5 under the Straits will not impair the public waters of the Great Lakes. This means that the State must demand full transparency and disclosure of all Enbridge’s activities not only for the people within range of a potential catastrophic spill, but for all residents of Michigan. Thus, if and when Enbridge decided to transport any type of heavy tar sands oil through Line 5, Enbridge has a duty to inform the state and the public and secure proper authorization under the Great Lands Submerged Lands Act. That’s FLOW’s take on the issue, and it’s what you will be hearing more about in the weeks and months to come. Stay tuned.

LivingstonDaily.com: ‘A lot at stake’ for locals regarding fracking rules

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‘A lot at stake’ for locals regarding fracking rules

Environmental group discusses options at Fowlerville meeting

A note from FLOW Chair Jim Olson to clarify – At the meeting, FLOW did say townships could undertake a ban, however we specified that it would be difficult to defend a ban, although you cannot preclude some circumstances where it may well be proper, because there is no place suitable where it could occur. But it is more likely, and better, that these issues and concerns are based on a case-by-case review through a zoning special use permit or other similar proceeding under the zoning or a police power ordinance.

By Christopher Behnan

February 6, 2014

FOWLERVILLE, MI – Local governments can use existing law and amend their own rules to regulate — if not outright ban — hydraulic fracturing in their backyards, For Love of Water representatives told local officials Thursday.

For Love of Water, or FLOW, was hired by Conway Township to discuss local rights after a Texas oil giant was permitted to inject 3 million gallons of water, sand and chemicals to maximize the potential recovery of natural gas at a local farm property.

FLOW Chairman Jim Olson said Michigan’s Zoning Enabling Act — which does not allow prohibition of drilling projects — empowers local governments to regulate everything from noise, hazardous materials and air pollution, to chemical mixing, storage and pumping activities at drilling sites.

Jim Olson, chairman of For Love of Water, explains the possible legal approaches that might be taken to regulate hydraulic fracturing, or 'fracking,' Thursday evening at the Alverson Center for Performing Arts at Fowlerville High School. / ALAN WARD/DAILY PRESS & ARGUS

Jim Olson, chairman of For Love of Water, explains the possible legal approaches that might be taken to regulate hydraulic fracturing, or ‘fracking,’ Thursday evening at the Alverson Center for Performing Arts at Fowlerville High School. / ALAN WARD/DAILY PRESS & ARGUS

Olson said local governments also can require environmental-impact statements and bonding for some activities, and address concerns such as lighting and dust control on local roads.

“Local communities have a lot at stake, and the question we started asking about a year-and-a-half ago was, ‘What can local units do?’ ” Olson explained.

“This is all basic stuff to address what is coming,” he added.

Local governments, in defending the public’s health and safety, could have legal standing to ban or place moratoriums on fracking but would face much bigger legal challenges, Olson added.

Just over 100 people attended Thursday’s session, which was intended to educate local leaders on high-volume hydraulic fracturing and their legal ability to regulate drilling-related activities in their communities.

FLOW will ultimately deliver a legal analysis based on Conway Township’s concerns, then leave it to the township attorney to draft ordinances.

FLOW Executive Director Liz Kirkwood said the Conway site is one of 52 permitted projects that allow high-volume fracturing to tap oil or natural gas reserves.

Kirkwood said large volumes of local water usage for projects and hauling of “flowback” water from wells should be of top concern to local leaders.

“This is just another industrial use that is coming to your town,” Kirkwood said.

Cohoctah Township resident Arnie Nowicki asks a question about water quality during Thursday evening's meeting in Fowlerville. / ALAN WARD/DAILY PRESS & ARGUS

Cohoctah Township resident Arnie Nowicki asks a question about water quality during Thursday evening’s meeting in Fowlerville. / ALAN WARD/DAILY PRESS & ARGUS

John Simaz, a spokesman for the oil and gas industry, accused FLOW of using “backdoor” methods to attack a decades-old, environmentally safe practice that creates jobs and boosts the economy.

Olson noted that high-volume projects only emerged in Michigan a few years ago.

About 20 wells have been drilled in Michigan using high-volume hydraulic fracturing over the past few years.

Texas-based GeoSouthern Energy Corp. in September was issued the high-volume drilling permit in Conway.

GeoSouthern’s permit allows the company to drill about 4,400 feet into the ground and about 1 mile horizontally into a geological formation known as A-1 carbonate starting on resident Jack Sherwood’s farm property off Fowlerville Road.

Sherwood has said he doesn’t expect the process to yield much. His farm property has been drilled three other times over the past 30 years, and in all cases, the drills came up dry.

GeoSouthern to date has drilled an exploratory well and is awaiting results of rock samples that will determine whether there is enough product to justify the expense of hydraulic fracturing.

Results of the samples aren’t expected for at least another three weeks.

Contact Daily Press & Argus reporter Christopher Behnan at 517-548-7108 or at cbehnan@gannett.com. Follow him @LCLansingGuy on Twitter.

FLOW Selected as Great Lakes Information Network (GLIN) Site of the Month

Click here to view the full press release as a PDF

FOR IMMEDIATE RELEASE
Contact: Allison Voglesong, Communication Designer
allison@flowforwater.org or 213-944-1568

FLOW Selected as GLIN Site of the Month

February 2014 to Feature FLOW

TRAVERSE CITY- The Great Lakes Commission-based Great Lakes Information Network (GLIN) has named FLOW their Site of the Month for February. As a GLIN partner, FLOW is honored to contribute to their outstanding resource network.

GLIN is a partnership that provides one place online for people to find information relating to the binational Great Lakes-St. Lawrence region of North America. GLIN offers a wealth of data and information about the region’s environment, economy, tourism, education and more.

FLOW is a non-profit organization working to ensure the waters of the Great Lakes are protected now and for future generations by recognizing the Great Lakes as a Commons, building deep public awareness and engaging the public and decision-makers about the threats and abuses facing the Great Lakes, and advancing public trust solutions to protect the rights of the people and waters of the Great Lakes Basin.

Because partnership is the core of GLIN, each month they highlight the wealth of information available on the web site of one active GLIN partner. These partners work closely with the GLIN Project Team to ensure that their information is integrated into the regional network; in turn, these partners point back to relevant GLIN pages from wherever appropriate on their own web sites so that people can easily find information about a topic of interest.

More on GLIN at http://great-lakes.net
More on FLOW at http://flowforwater.org

Require Cumulative Environmental Impact Statement for Keystone XL and Alberta Clipper Tar Sands Oil Pipelines

FLOW, along with a myriad of policy and environment groups throughout the Midwest led by Sierra Club, signed this coalition letter to Department of State Secretary John Kerry. The letter requests that the Department of State consider developing a supplemental environmental impact statement (SEIS) for the Keystone XL pipeline that also accounts for the Alberta Clipper pipeline for the purpose of analyzing the “cumulative climate impacts” of both proposed tar sands oil routes. It got some recent news play via Bloomberg, which identifies that even if the petition letter to Department of State Secretary John Kerry was rejected, it “could be the foundation for a legal challenge.” (You can also read the full text of the Bloomberg article at the bottom of this post.)

In a nutshell: it is insufficient to evaluate the climate impacts of each of these pipelines independently through separate EISs, and we urge the Department of State to develop an SEIS for the Keystone XL pipeline that examines the consequences of both pipelines’ combined climate impacts before reaching a decision on either pipeline proposal.

Why we care: FLOW believes that legally requiring the consideration of both pipelines’ cumulative climate impact presents an opportunity to account for the potential risks and impacts that these pipelines pose to the Great Lakes. As these lakes are protected as a public commons and public trust, it is the duty of the Department of State to ensure that the proposed pipelines will not impair the Great Lakes with the destructive climate impacts they will surely create.

The letter argues that the Department of State’s Keystone XL Draft Supplemental Environmental Impact Statements (DSEIS) downplays the pipeline’s connection to the larger climate impacts of a fast-growing tar sands oil industry. The DSEIS posits that the tar sands industry would seek ways to increase oil development capacity even without the Keystone XL pipeline and will thus have the same, inevitable climate impacts no matter what. However, the Department of State announced that it will also consider a Presidential Permit for the Alberta Clipper tar sands oil pipeline expansion project. This proposal would contribute to a greater increase in tar sands oil development than that which is considered in the Keystone XL SDEIS. Therefore it is critical for the Department of State to consider the climate impacts of the Keystone XL within the context of an even greater increase in greenhouse gas emissions as a consequence of the proposed Alberta Clipper pipeline.

To summarize the points and legal analyses of the letter:

  • The National Environmental Policy Act requires an analysis of the cumulative effects of reasonably foreseeable projects,
  • the Keystone XL DESIS fails to consider the Alberta Clipper expansion,
  • the Department of State must evaluate the cumulative impacts of Alberta Clipper and other proposals in the Keystone XL EIS,
  • new information shows that Keystone XL will directly contribute to tar sands oil expansion and increased global carbon pollution,
  • new information shows that rail cannot replace Keystone XL and other tar sands pipelines,
  • tar sands pipelines are inadequately regulated and unsafe, and TransCanada has demonstrated a dismal safety record, and
  • there are demonstrated contractor conflicts of interest and failure by the Department of State to ensure a thorough and unbiased analysis, which may invalidate findings of the DEIS.

FLOW applauds the Sierra Club for leading the way on this petition, and continues to engage with this coalition and through our own work to protect the Great Lakes and all our common waters from the risks of climate change and extreme energy development.

In addition to supporting this request for a supplemental environmental impact statement, FLOW is specifically interested in requiring that a primary goal of tar sands development be the protection of the Great Lakes. Haphazard tar sands oil development threatens devastating  effects on the water of the Great Lakes as well as its people, businesses, ecosystem, and economy.  The Great Lakes are irreplaceable and undue risks or overwhelming potential harms, such as these proposed tar sands pipeline expansions, are unacceptable and do not comport with the rights of the public under the public trust principles that protect the Great Lakes.

Follow our work on the “nexus” between water, food, energy, and climate change issues hereRead the whole letter here. Read the full Bloomberg article below or at this link.

Keystone Foes Say Two Pipelines Are Worse Than One

By: Mark Drajem, Bloomberg News

January 30, 2014

Opponents of Keystone XL now want to block its construction by showing that two oil pipelines from Canada to the U.S. are worse than one.

The Sierra Club said TransCanada Corp.’s (TRP) Keystone and the proposed expansion of Enbridge Inc.’s (ENB) Alberta Clipper should be reviewed together to account for how the combination would contribute to climate change. The San Francisco-based environmental group filed a petition today with 15 other groups, asking the U.S. State Department to revise its Keystone review.

“If you look at each project in isolation, it doesn’t present the full picture,” Doug Hayes, the Sierra Club lawyer who drafted the petition to Secretary of State John Kerry, said in an interview. “They need to look at the two projects together to see if there will be a climate impact.”

Accepting the petition could lead to further delays in the U.S. review of the Keystone application, which is already in its sixth year. Even if the State Department rejects the Sierra Club’s argument, the petition could be the foundation for a legal challenge, said Ethan Strell, associate director of Center for Climate Change Law at Columbia University in New York.

TransCanada, based in Calgary, said environmentalists will never be happy with the State Department review, which has generated thousands of pages of analysis.

More ‘Ridiculousness’

“This is more of the ridiculousness from the activists who are trying to come up with anyway to” block Keystone, said Shawn Howard, a company spokesman. “At what point does this stop? At some point the process needs to come to a conclusion.”

The Sierra Club said the State Department has to account for its authority over oil sands development, because the two pipelines combined could carry almost 1.3 million barrels a day. By considering each application separately, it’s not taking into account the full impact, according to a copy of a petition to the government provided to Bloomberg.

The State Department reviews permit applications for pipelines that cross international borders. President Barack Obama pledged in June to approve Keystone only if it wouldn’t “significantly exacerbate the problem of carbon pollution.” Enbridge is seeking to expand its Clipper pipeline to carry more oil than is planned for Keystone.

Scientists say carbon-dioxide emissions from burning fossil fuels such as oil and coal contribute to global warming. Environmental activists say Keystone and the Alberta Clipper would lead to greater production of Canada’s oil sands, which are more carbon intensive than traditional crude.

Alberta Crude

A draft State Department report in March reached the opposite conclusion about Keystone. It said other pipelines or more rail transit would be developed to get the oil out to refineries even without the proposed $5.4 billion Keystone project, which would link Alberta crude to refineries along theGulf of Mexico.

Enbridge’s project runs from Alberta to Superior, Wisconsin.

If the rejection of one pipeline would lead to greater use of the other, then the projects should be considered together, Hayes said.

Columbia University’s Strell said the Sierra Club argument has merit and could be the basis for a lawsuit under the National Environmental Policy Act, or NEPA.

‘Cumulative Impacts’

Under the law, “you would have to consider the cumulative impacts,” Strell said. “Certainly, it’s a very common challenge under NEPA.”

Environmental groups separately have been pressing for the final State Department analysis to account for limits on another transport option, rail. If it’s not feasible to move the expanding quantities of oil using rail, the pipeline would become the culprit in worsening climate change, they said in a meeting last month with State Department officials.

New regulations proposed by transportation safety investigators in the U.S. and Canada last week after a spate of oil-train accidents could limit the ability of rail to haul more oil.

TransCanada filed its initial application for Keystone XL, which would carry 830,000 barrels per day, in 2008. Calgary-based Enbridge applied in November 2012 to add pumps and valves to a portion of its Alberta Clipper to increase capacity to 880,000 barrels a day from 450,000 barrels.

“The Alberta Clipper expansion is a very different project from Keystone XL, involving increasing the horsepower on an existing pipeline (Line 67) within a well-established right of way, with no new pipeline construction or ground disturbance,” Larry Springer, an Enbridge spokesman, said in an e-mail.

The State Department is working on the environmental reviews of each application. Once those are complete, the Obama administration must decide if each is in the national interest.

To contact the reporter on this story: Mark Drajem in Washington at mdrajem@bloomberg.net

To contact the editor responsible for this story: Jon Morgan at jmorgan97@bloomberg.net

Pennsylvania Court Precedent on Fracking and How It Relates to Protecting Michigan’s Commons: PA State Supreme Court rules municipalities can limit what gas drillers can do

From the desk of FLOW founder Jim Olson: thoughts on the recent Pennsylvania Supreme Court ruling on how municipalities can limit gas drilling in their community (you can also read the full text of the TribLive.com article at the bottom of this post).

In a show of judicial analysis and sympathy toward the importance of land use stability and values of local communities, the recent Pennsylvania Supreme Court’s ruling upholding local government regulation of the risks of fracking sends a strong message: courts will look with skepticism and scrutinize attempts by state legislators to help special interests overrun local communities’ traditional land use and police powers to pass ordinances that address fracking for oil and gas. The decision is especially important in consideration of mainly vacuous federal regulation and tepid state regulation, where fracking’s substantial effects on land use, water, health, and quality of life are largely ignored.

In sum, the court’s decision refuses to allow a state legislature to take away local governments’ zoning or local power regarding expectations of their community and residents, thus upholding and retaining local governments’ ability to have a say in the location of land uses and the stability of their community, including regulation of industrial uses like fracking through land use districts and special use permits. This precedent is important for other Great Lakes states like Michigan with a long and strong history of enabling local governments with zoning powers because it protects their ability to use zoning powers as a legal and useful tool for protecting land uses, water, air, and health from the impacts and risks of fracking. Click here for more about FLOW’s local government ordinance program to address fracking impacts at the community level.

In December 2013, the Pennsylvania Supreme Court tossed out controversial portions of the state’s oil and gas law changes, letting municipalities retain control over where and when to allow gas drilling (fracking) in their jurisdictions. This is great news for Pennsylvania, and can be good news for local governments in other states as well. However, from state-to-state the laws are somewhat different, so while the ruling reveals a trend that is positive for empowering local governments to address fracking, it is not on “all fours” as we say in terms of useful precedent, and may not necessarily apply verbatim to other states. Thus, it is important that citizens and communities understand the differences of their own state and local government structures and laws so that communities can tailor their ordinances and regulation of various aspects of fracking and ancillary oil and gas uses and activities.

Basically, Pennsylvania’s prohibition on local regulations/ordinances was general in nature as to “oil and gas operations.” Since zoning power was and is delegated by states as a “state delegated specific power” and Pennsylvania zoning law does not exempt regulating the location of oil and gas operations or wells as land uses through districts and permitting schemes, the Pennsylvania court properly found that a general law prohibiting exercise of local governmental police power cannot be used to trump or limit a specific delegation of power like zoning. The Pennsylvania court also chastised the legislature for an overly general and vague prohibition, thus leaving room for local governments to exercise some power, and specifically their delegated zoning power. However, the Court also refused to allow the state legislature, by a broad sweeping law, to remove or take away zoning or the general exercise of local ordinance powers regarding expectations and reliance of communities and their residents on the stability of their land use plan and ordinances. This general reasoning is very important in states like Pennsylvania, Ohio, and Michigan, with strong local government traditions and involvement, including specified powers or preferences toward local governments in state constitutional provisions.

Here are five key points (with a few nuances) about how the Pennsylvania ruling relates to Michigan:

  1. In Michigan, there is no general prohibition on local governments to pass “police power” ordinances to address risks and harms and protect property, health, safety and general welfare. Hence, local governments in Michigan are free to regulate to the point that the ordinance does not outright prohibit a use but addresses the risks of harm or concern for protection of the public health, safety and welfare.
  2. Unlike Pennsylvania, in Michigan the state-delegated zoning statute to counties and townships specifically exempts “oil and gas wells, drilling, completion, production, and closure or abandonment.” However, the exemption is a narrow one. The Michigan Supreme Court has ruled that the “oil and gas well” exemption does not apply to ancillary uses and facilities related to oil and gas wells, such as pipelines, access roads, haul and transfer facilities, storage, sweetening facilities, pumps, and high-volume water wells such as those required for horizontal fracturing. At least as to the location of such wells and related facilities, a special use permit or other zoning regulation to assure compatibility with existing land uses, water uses essential to a land use district such as farming, residential, or park and recreation, could be required.
  3. On the other hand, like Pennsylvania, in Michigan there is no such specific exemption for “oil and gas wells” in the state delegated zoning power to cities. So, unlike townships and counties in Michigan, cities are similar to the Pennsylvania situation. If the legislature attempts to prohibit generally what the zoning power to cities specifically allows, i.e. does not exempt, the Pennsylvania case would be useful precedent
  4. In Michigan there are limitations, although not outright prohibitions, on local government police power ordinances that regulate the location of public utilities or natural gas or other pipelines that are certified by the Michigan Public Service Commission (with the exception of interstate federally certified lines, which are not subject to local ordinances). However, local governments, in these instances, may require by ordinance essential or critical information concerning:
    • use and safety of roads,
    • environmental and hazardous substances disclosures,
    • including chemicals,
    • bonds, indemnities, and insurance,
    • site plans,
    • reporting and inspection reports, and
    • action plans in the case of spills or emergency.
  5. Michigan’s 2008 water withdrawal law, with its corollary Water Withdrawal Assessment Tool (WWAT) contains a provision that prohibits local ordinances from regulating water withdrawals. However, this law does not regulate or address land use or zoning, such as the location, site plan, and facilities themselves. It follows that local communities could, through their state-delegated zoning power, regulate the location of water wells to assure they are harmonious and not incompatible with existing land uses.
    • It would be quite reasonable for a local community to restrict high-volume water wells, pumps, and facilities and pipelines through land use districts or special use permits. Indeed, the Pennsylvania court decision would provide solid precedent for this, because, as described above, a general prohibition on local ordinances would not preempt or limit the scope of specifically state-delegated zoning power.
    • So when it comes to high-volume water wells for oil and gas development, local communities should be able to regulate them through zoning. Why? Because for townships or counties, water wells are “ancillary” to the oil and gas well and therefore not within the “oil and gas well” zoning exemption, and for cities because there is no oil and gas exemption in the city zoning law.
    • Finally, in a somewhat ironic twist, the 2008 water withdrawal law expressly exempts oil and gas development from having to comply with the WWAT or 2008 water withdrawal law. Hence, arguably it would be inconsistent for an oil and gas company to argue that local governments could regulate their water withdrawals when they do not need a permit or fall with the regulatory purview of the water withdrawal law in the first place.
    • But there is another twist to the irony. The Michigan Department of Environmental Quality (DEQ) by internal directive requires oil and gas companies to comply with the WWAT to show no adverse environmental impacts. However, no permit is required under the 2008 water law, and the DEQ directive is more lenient in its application than the WWAT and its application and permitting requirements. Despite these twists, local governments, in any event, have the zoning power to restrict or require special use permits for high-volume water wells based on location and land use issues as opposed to withdrawal issues.

In conclusion, Michigan law already empowers local governments with a broader and more effective ability to address fracking impacts via municipal zoning and police power ordinances. However, this Pennsylvania Supreme Court case is still very relevant for supporting the broader effort throughout the Great Lakes and Midwest region to protect our land, water and common resources, and community well-being from a loosely regulated in terms of land use and impacts of fracking oil and gas development.

-Jim Olson

Read on for the full story from TribLive.com

PA State Supreme Court rules municipalities can limit what gas drillers can do

December 19, 2013

By: Timothy Puko, Pittsburgh Tribune-Review

After nine years of drilling, three years of debate and 14 months of court deliberation, Pennsylvania is back where it started, with shale gas companies and municipal governments at odds over how to manage the Marcellus shale natural gas boom.

The State Supreme Court ended more than a year of uneasy stalemate on Thursday when it struck down oil and gas law reforms that were supposed to limit municipal powers on drilling. The 4-2 decision allows municipal governments to keep blocking off some, though not all, of their neighborhoods from drilling, and subjecting drillers to reviews before permitting drilling.

The long-awaited decision undoes a key element of Gov. Tom Corbett’s signature legislation: It strips the oil and gas law reforms known as Act 13 of the biggest benefit they gave drilling companies. It gives environmentalists and municipal governments a potentially historic precedent to challenge drilling all over the state, reigniting legal battles that were brewing before the case went to state courts last year.

“It’s a great day for all the residents here in Pennsylvania,” said Deron Gabriel, commissioner in South Fayette, one of five Pittsburgh suburbs to lead the legal challenge that started in March 2012. “Fundamentally, we’re vindicated. … We’re able to continue to zone and keep industrial activities where they should be — in industrial areas.”

Both Corbett and members of the Marcellus Shale Coalition industry group called the decision a disappointment. Officials of the coalition and the Pennsylvania Independent Oil and Gas Association said they want to work with municipal groups to find solutions to their conflicts.

“We must not allow (Thursday’s) ruling to send a negative message to job creators and families who depend on the energy industry,” Corbett said. “I will continue to work with members of the House and Senate to ensure that Pennsylvania’s thriving energy industry grows and provides jobs while balancing the interests of local communities.”

The passage of Act 13 culminated three years of debate on how to modernize the state’s rules to manage the new rush of shale gas drilling. Horizontal drilling and hydraulic fracturing began in the Marcellus shale about nine years ago, booming to more than 7,400 unconventional wells statewide, according to state records.

Passed in February 2012, Act 13 was supposed to have a three-pronged effect. Two — an update to environmental protections and a fee on deep-shale wells — remain. But the effort to help drillers by making uniform land-use laws in all 2,500 municipalities was part of the challenge and the part the court struck down.

The rules would have required municipalities to allow drilling, wastewater pits and seismic-testing explosives even in residential areas, which Chief Justice Ronald D. Castille called a “remarkable … revolution” on existing law. It would have allowed pads within 300 feet of existing buildings, which Castille said effectively stripped municipalities’ ability to plan for development.

Municipalities previously had the power to decide where and when drilling could happen, and South Fayette, Cecil, Peters, Mt. Pleasant and Robinson in Washington County sued to keep that power. The law put them in conflict with a constitutional mandate to protect residents and property rights by not allowing them to keep drilling away from schools, parks and businesses, they argued.

The Supreme Court heard the case in October 2012 and took 14 months to craft a broad, 162-page decision. Castille wrote it for three members of the majority, and a fourth wrote a concurring opinion. Castille, a Republican Vietnam War veteran and former Philadelphia prosecutor, wrote at length about the state’s history of environmental degradation.

He quoted a passage on deforestation from the timber industry, listed a series of local environmental disasters including the 1948 Donora smog tragedy and noted the billions needed to repair decades of environmental damage from coal mining, which he later said may be rivaled by shale gas extraction. The state has a “notable history of what appears retrospectively to have been a shortsighted exploitation of its bounteous environment,” Castille wrote.

His argument attempts to re-establish the importance of the state Constitution’s Environmental Rights Amendment, the pivotal law cited in his opinion. That amendment empowers municipalities to protect the environment, and the state overstepped its powers by ignoring it, forcing them to accept uniform rules for gas drilling, Castille said.

“A new regulatory regime permitting industrial uses as a matter of right in every type of pre-existing zoning district is incapable of conserving or maintaining the constitutionally protected aspects of the public environment and of a certain quality of life,” he wrote. “Protection of environmental values … is a quintessential local issue that must be tailored to local conditions.”

The ruling is likely to trigger a flurry of activity from drilling industry lobbyists and lawyers, experts said as they awaited the high court’s decision.

The industry may pressure state lawmakers to try again to streamline rules. One option may be to write a model ordinance for municipalities, then pass a law that allows them to collect impact fees only if they use that ordinance, said Ken Komoroski, an attorney at Downtown-based Morgan, Lewis & Bockius LLP.

“If they can’t do it with a sledgehammer, they’re going to have to do it with a carrot,” attorney Kevin McKeegan, a land-use law expert with Meyer, Unkovic & Scott LLP, Downtown, said last December.

Timothy Puko is a staff writer for Total Trib Media. Reach him at 412-320-7991 or tpuko@tribweb.com.

FLOW Staff to Issue Public Statement at Army Corps of Engineers Public Comment Forums on the Great Lakes Mississippi River Interbasin Study

Click here to view and download the full press release PDF

For immediate release
Contact: Allison Voglesong, Communication Designer
231 944-1568 or allison@flowforwater.org

FLOW Staff to Issue Public Statement at Army Corps of Engineers Public Comment Forums on the Great Lakes Mississippi River Interbasin Study

TRAVERSE CITY – The United States Army Corps of Engineers (ACE) public comment forums on the Great Lakes Mississippi River Interbasin Study (GLMRIS) report makes the fifth of nine stops in Traverse City, MI on Thursday, January 23, 2014. FLOW, a Traverse-City based nonprofit water policy and education center, has prepared written comments and will make public statements during today’s forum that seeks public input on the new GLMRIS report. The study enumerates eight plans for keeping invasive species, namely Asian Carp, out of the Great Lakes. FLOW encourages the ACE to implement plans that undertake complete hydrologic separation of the Great Lakes Basin and the Mississippi River Basin.

“We need strong Great Lakes policies that protect water quality and quantity, and ensure that invasive species never reach our common waters of the Great Lakes,” says FLOW Communication Designer Allison Voglesong. The present systems for keeping invasive Asian Carp out of the Great Lakes are a series of electrical barriers, but these alone are insufficient, and additional measures are needed urgently.

“To address this complex ecological and multi-jurisdictional problem, there must be a complete hydrologic separation between the Great Lakes Basin and the Mississippi River Basin,” says Voglesong. Cost estimates for ACE plans including complete hydrologic separation vary, upwards of $15 billion in some cases. “From an economic standpoint the Great Lakes support a $7 billion fishery and a $62 billion overall economy,” she says, “There is too much at risk, and the cost of inaction will be far greater than the investments considered here today.”

Voglesong outlines three statements and three questions for the ACE to consider:

  • The 25-year implementation timeframe is too long, and we urge research into a realistic but shorter timeframe;
  • The research in the GLMRIS study is thorough, but the public and our decision-makers need better guidance from the agency for prioritizing possible solutions;
  • We are proponents for plans that establish complete hydrologic separation for all five possible pathways.
  • Is it economically and logistically feasible to scale back portions of these plans that are outside of the scope of managing invasives, such as water treatment, sediment remediation, and flood mitigation?
  • And, are there risks with eliminating these components?
  • Could other plans for complete separation, like those released by GLC and the Cities Initiative, be substituted or reconciled with your complete separation plans to find an economically viable middle-ground?

Voglesong urges the long-term implications of the plan. She says, “Doubtless, there are incomparable, difficult tradeoffs involved in solving this problem. The bottom line, however, is that we must protect the delicate ecological balance of the Great Lakes from destructive invasive species because the waters of the Great Lakes Basin are our shared commons, and our legacy for generations to come.”

Michigan Corps Member Spotlight: FLOW

Click here to read the article on Michigan Corps’ site

For more about Michigan Corps, click here to visit their site.

By Jason Aoraha

Jim Olson has been practicing environmental law for forty years. In recent years, the Northern Michigander began asking himself how he could bring a group of concerned citizens together to protect water and natural resources under an ancient doctrine known as the public trust, which demands stewardship of our water resources – from navigation to drinking water to recreational needs. He founded FLOW (For Love of Water) to bring Michigan citizens together to protect our state’s most coveted natural resource, and the largest group of freshwater lakes on Earth, the Great Lakes.

FLOW’s mission is to advance Great Lakes policies and solutions that protect our common waters. This year, FLOW entered Michigan Corps’ first Social Entrepreneurship Challenge, and emerged a finalist for their unique policy and education programs that empower individuals with solutions to protect the integrity of Michigan’s waters. Based in Traverse City, FLOW is in a great position (both figuratively and literally) to empower citizens, decision-makers, and legal advocates alike with guidelines on how to protect the Great Lakes.

Founder Jim Olson expresses the passion of a social entrepreneur out to protect and build stewardship of our environment. “FLOW’s work is grounded in reality and a fundamental human value: Water is life. Water runs through every aspect of human endeavor and community. If we protect the integrity of this water, in both quantity and quality, we will sustain life, economy, and community. After all, there is no green without blue,” he says.

FLOW participated as a star contestant in our 2013 Pure Michigan Social Entrepreneurship Challenge with their focus on harnessing the passion of individuals to make a difference surrounding the future of our Great Lakes. We were impressed with FLOW’s focus on scaling their impact through partnerships with organizations that shared their passion, such as the Michigan Environmental Council, Michigan Land Use Institute and others. The team at FLOW understands that to change society for the better, we must build the capacity of our organizations and one another to create groundbreaking policies that address pressing concerns surrounding the future of our waters. Most recently, FLOW pioneered Great Lakes policy and education for citizens and planning officials to suggest improvements to local government ordinances pertaining to the environmental impact of fracking for oil and natural gas extraction.

Following the conclusion of the Social Entrepreneurship Challenge, FLOW joined Michigan Corps’ first cohort of Social Enterprise Fellows. The Fellowship training program helped FLOW evaluate their programming and diversify opportunities for citizens to interact with FLOW’s policy, education, and Great Lakes Society programs.

FLOW and its members are striving to make the Great Lakes a beacon for groundbreaking environmental stewardship. This year, FLOW plans to bring Maude Barlow, a world leader in global water policy and crisis affairs, to Detroit to help catalyze local thought leadership and action surrounding the future of our Great Lakes.

Entrepreneurial thinking is giving FLOW a new perspective on Great Lakes development and advocacy work. If you’re passionate about the Great Lakes, and want to connect with one of the most pioneering organizations involving Michigan’s fresh water – visit flowforwater.org and consider becoming a Great Lakes Society member. It’ll make your next trip to Traverse City that much more meaningful! Also make sure to check out their programs, special public events and up to the minute blog.

Let’s Get Together

The Great Lakes Society was formed to sustain the work of FLOW. Now the Great Lakes Society wants to encourage others to join and participate with comments, suggestions for how the Society can foster FLOW’s work to find and apply solutions to address the systemic threats to the Great Lakes. You can join the Great Lakes Society here.

I like working in groups and working with people because of the team dynamic, the camaraderie, the exchange of ideas; all these intangible benefits are valuable aspects of being a member of a group. The French philosopher Alexis de Tocqueville noted that the key to the United States’ successful democracy was the variety and volume of associations in civil society. (In 1835) Tocqueville said that “knowledge of how to combine is the mother of all other forms of knowledge; on its progress depends that of all the others.” That is to say, our groups, societies, clubs, and teams facilitate the broader democratic process simply through the exchange of ideas that occurs when we collaborate.

These benefits are why belonging to associations can improve the quality of our lives, and it’s why I joined FLOW’s Great Lakes Society this year as a Manitou Member. The Great Lakes Society is a group that does so much more than support FLOW’s work financially. It is a group that is chock full of passionate and motivated people committed to protecting the Great Lakes with great laws, and FLOW brings them all together to create a sum greater than its parts.

room full of guests - Copy

Great Lakes Society members at our Annual Celebration came from across Michigan, Illinois, New York, and Ontario, Canada.

The Great Lakes Society is building a collaborative network of individuals who care about the Great Lakes. Memberships come from across the Great Lakes Basin in Illinois, Indiana, Michigan, Minnesota, New York, Ohio, and Wisconsin, as well as from Colorado, Washington DC, Kentucky, Washington. We are also growing our Great Lakes Society in Canada, starting in Ontario.

Our members represent many areas of expertise, from high-caliber natural resources policy experts such as Maude Barlow from the Council of Canadians and Wenonah Hauter from Food & Water Watch, to renowned poets such as Michael Delp and James Lenfestey, to professionals in government, professors, leaders in business, experts in the renewable energy industry, to doctors and lawyers and filmmakers, teachers and farmers, grassroots activist and students. The list goes on.

I had the great pleasure of organizing (along with an excellent contingency of generous volunteers and Society members) the inaugural Annual Celebration of the Great Lakes Society this past August. My fellow Society members are so different, yet alike in their passion for and engagement in the preservation of the Great Lakes’ common waters. I was delighted by the day’s art, music, and culinary indulgences (including great beer) and even more delighted by the conversations I had with fellow Society members. I was engrossed in discussions of inspiring, various topics, such as how to go about commissioning a Great Lakes Symphony (think Holst’s Planets, but with five Great Lakes instead) and use music as a catalyst for promoting Great Lakes education. Or how to connect the idea of “virtual” and “embedded” water consumption to use of everyday consumer items, perhaps expanding on our Beans4Blue coffee to include things like beer, or clothes. Of course there was plenty of discussion about how climate change has affected our Great Lakes.

A sign of good beer

A good sign at The Workshop Brewing Company where we hosted the inaugural Annual Celebration of the Great Lakes Society

I was not surprised by the level of intelligence and awareness of my fellow Society members, rather I became even more inspired to help FLOW take our work to the next level and find workable solutions to the systematic threats facing the Great Lakes we all so deeply care for.

The Great Lakes Diaspora

This time of year I’ve been working (again with our dedicated volunteers and Society members) to expand our Great Lakes Society through our holiday membership drive. From organizing the databases to dreaming up the letters and emails to nursing the inevitable paper cuts that come with stuffing envelopes, it’s been quite a journey. One of our volunteers even said he had a dream (or was it a nightmare?) about licking envelopes after one long night of work.
Throughout this process I’ve become familiar with our members and our followers, and I noticed that so many of our followers are spread out far beyond the Great Lakes Basin. Our care for and love of the Great Lakes follows us wherever we live, these lakes are truly that valuable and magnificent. We are growing our membership and as it continues to spread out geographically we are also working on new ways to bring our Great Lakes Society members together virtually. This is to promote members’ engagement and collaboration with FLOW on our policy work, as well as with each other.

In the spirit of Tocqueville, in the spirit of cooperation, and in the spirit of collaboration, I’m asking you to leave a comment and let us know, what are some ideas you have for creating a more inclusive Great Lakes Society community that promotes the exchange of ideas and improves interpersonal connections among members? We’re open to your feedback, and of course, we hope you join us and become a member of the Great Lakes Society today.