Lake Michigan lovers, unite! US EPA has scheduled a Public Hearing on the draft injection well permits at the Campbell Plant. The ONLY reason this hearing got scheduled is because YOU–194 of you, to be exact–used your voices and told US EPA you had concerns. EPA is NOT required by law to do this. It is at their discretion.

So now what? It is important that we finish the job, and show up to the public hearing. I can tell you from my own experience working for the Michigan DEQ (now EGLE)–the state’s environmental regulatory agency–public comment at a public hearing matters.

We likely CAN’T stop the issuance of the permits, but we likely CAN get them to consider adding protective permit conditions IF ENOUGH OF US SHOW UP AND SPEAK UP.

What do we want?

As much assurance as possible that the waste plumes from these wells will not migrate to Lake Michigan.

Why do we need such assurance?

Because the current “assurance” is all based on modeling and assumptions about how the deep waste plumes will behave over time. It will likely not be based on data, and not on any monitoring requirements for the waste plume itself. With any other above-ground form of waste disposal, there are monitoring requirements so that we can be assured that the waste is not affecting sources of groundwater and surface water. With this, there will likely be shallow monitoring wells to detect spillage or overflow-type mistakes at the injection point. But there will likely be NO monitoring of the behavior of the deep waste plume itself.

What permit conditions could provide us such assurance?

1. An independent review of the modeling, seismic and geological assumptions for these permits, by an engineering firm engaged by US EPA or EGLE, not Consumers Energy.
2. A requirement for monitoring wells at the boundary of the Area of Review, including several at maximum depth between the waste plume and Lake Michigan, and a requirement for periodic updated modeling reports based on data from the monitoring wells.
3. A requirement for use of chemical tracer testing in monitoring wells.

Please put the evening of July 23 on your calendars. Plan to attend, even if you’re not comfortable speaking. If you think you might be able to say just a few words in public comment, it would go a long way toward protecting the lake we all depend on. Here is the EPA announcement with details of the meeting.

An overview of Concerns re: siting deep waste injection wells near Lake Michigan

At the public hearing, you’re likely going to hear from regulators that there are already injection waste wells sited near the lake, and they’ve been operating without incident. The injection wells already sited along Lake Michigan are disposing of food processing waste (brine), not the ethyl-methyl-badstuff that’s in coal ash leachate. A big difference. And how does anyone know that there isn’t a looming “incident,” if there’s no monitoring of the waste plume? Everyone is just guessing.

Talking Points: Concerns with Deep Waste Injection Wells Near Lake Michigan

Geological & Structural Risks

• The Great Lakes region contains ancient fault systems and fracture networks that could provide unintended pathways for injected waste to migrate upward
• Induced seismicity from injection pressure can reactivate dormant faults, potentially creating new migration routes toward the lake
• Karst geology present in parts of the region creates unpredictable underground connectivity between formations
• Well casing failures or integrity breaches—which occur in a significant percentage of injection wells over time—can release contaminants into overlying aquifers

Proximity to a Critical Freshwater Resource

• Lake Michigan holds approximately 1/5 of the world’s surface freshwater; contamination would be catastrophic and largely irreversible
• The lake supplies drinking water to millions of residents in Illinois, Indiana, Michigan, and Wisconsin
• Contaminants migrating into connected groundwater systems could enter the lake through submarine groundwater discharge

Waste Plume Monitoring Failures

• Injection well permits frequently lack requirements for tracking subsurface plume movement after injection
• No standardized federal mandate exists requiring operators to monitor where waste migrates once it leaves the wellbore
• Underground plumes can travel miles from injection points over years or decades, yet most monitoring focuses only on the immediate well area
• Pressure monitoring at the wellhead does not capture lateral or vertical migration of the waste plume
• Baseline groundwater quality studies are often inadequate or absent before injection begins, making it impossible to detect contamination later
• Monitoring wells, when required at all, are often too few in number and poorly positioned to detect off-site migration
• There is no real-time public reporting requirement for plume movement in most state permitting frameworks
• By the time contamination is detected in drinking water or surface water, the plume may have been migrating for years

Regulatory & Oversight Gaps

• The Safe Drinking Water Act’s Underground Injection Control (UIC) program has long been criticized for inadequate enforcement and understaffing
• Class I hazardous waste injection wells require EPA or state permits, but Class II (oil & gas brine) wells have far weaker oversight despite high volumes
• State primacy programs vary widely in rigor; some Great Lakes states have weaker standards than federal minimums
• Permit reviews rarely account for cumulative impacts of multiple injection wells operating in the same region
• “Area of Review” calculations used to assess risk are often based on outdated or oversimplified geological models

Cumulative & Long-Term Risks

• Injected waste remains underground indefinitely; liability and monitoring obligations often end when a company closes or goes bankrupt
• Chemical interactions between injected waste and native brine or rock formations can produce secondary contaminants not originally present
• Climate change and changing precipitation patterns may alter groundwater pressure gradients, accelerating unexpected plume migration
• The long time horizons involved (decades to centuries) far exceed typical permit monitoring windows of 10–30 years

Stakeholder & Environmental Justice Concerns

• Communities of color and lower-income lakefront communities often bear disproportionate risk from industrial injection siting decisions
• Tribal nations with treaty rights to Great Lakes fisheries and water resources are frequently excluded from meaningful consultation
• Property values, tourism, and commercial fishing industries face existential risk if Lake Michigan water quality is compromised