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Request

Action: Notice, request for comments.

Web posting date: 08/31/2012

Federal Register Notice of Finding Publication Date: 12/12/12

Effective Date of Federal Register: 12/13/12

Close of public comment period: 12/28/12

Summary: The New International Trade Crossing (NITC) is a new border crossing proposed by the State of Michigan and the Government of Canada over the Detroit River linking Detroit, Michigan, to Windsor, Ontario that will support economic growth in the United States. While this project will be funded solely by Canadian public and private funds, with the project's Canadian partners assuming all the financial risk, the Canadian partners have agreed to permit the use of American and Canadian steel and iron in the construction of the NITC. Since Michigan intends to use the Canadian contribution as the State match on other Federal-aid highway projects, the NITC must comply with the FHWA Buy America requirements of 23 CFR 635.410. Therefore, the Federal Highway Administration (FHWA) is seeking comments on whether Michigan's request for a waiver of the requirements of 23 CFR 635.410 should be permitted in order to permit the use of American and Canadian steel and iron in the construction of the NITC.

FHWA will only consider such a waiver when the conditions of 23 CFR 635.410( c) have been met: (1) when the application of the provision would be inconsistent with the public interest; or (2) when steel and iron products are not produced in the United States in sufficient and reasonably available quantities, which are of a satisfactory quality.

Michigan offers the following background information and statements in support of their request: Canada is the United States' largest trading partner, supporting 8 million jobs in the United States and 3 million in Canada. As a result, the request emphasizes the importance of this project to the economic growth and security of both countries. Furthermore, a report by independent economists estimates that the construction of the NITC will directly create 10,000 temporary jobs in the United States. In light of Canada's financial contribution to this project, Michigan asserts that it is unlikely the project will move forward without the ability to use both American and Canadian steel and iron. Michigan proposes that the unique circumstances of this project support a determination that a waiver of Buy America is in the public interest in order to allow the use of both Canadian and American steel and iron in the construction of the NITC.

Request letter (available upon request)

The FHWA will consider all comments received in the initial 15-day comment period during our evaluation of the waiver request. Comments received after this period, but before notice of our finding is published in the Federal Register, will be considered to the extent practical. Follow-up coordination on the comments received may result in a delay in the publication of our waiver finding in the Federal Register. Comments received during the 15-day comment period after notice of our finding is published in the Federal Register will be reviewed, but the finding will continue to remain valid. Comments received during the comment period after the effective date of the finding will be reviewed, and may influence the FHWA's decision to terminate or modify a finding.

Comments

David Wresinski 09/04/2012
This project will construct critical infrastructure to support US/Canadian trade. The economic impact of this project will benefit our state and national economy. As such, I support this waiver.

Mike Guter 09/04/2012
The US-Canadian border in the Detroit area currently includes only two major crossings. The crossings used by the public are the Ambassador Bridge over the Detroit River completed in 1929 and the Detroit-Windsor Tunnel under the Detroit River completed in 1930. Both crossings are over 80 years old and are located geographically where it made sense in the early 20th century. Michigan’s aging infrastructure has been highlighted by the American Society of Civil Engineers (ASCE) Michigan Section infrastructure report card. The 2009 report gave Michigan’s transportation infrastructure a grade of D, primarily due to the age and inadequacy of the transportation system. This border area, where updates to the infrastructure are absolutely necessary, is a prime example of aging infrastructure and lack of capacity.

Canada is assuming financial risk for this project as they desperately need a freeway to freeway link to the border in the Windsor area. Imposing a Buy America provision for steel and iron that does not include Canada is unfair. There are financial implications to the project and therefore financial implications for Canada when the competitive marketplace is limited. In this case, Canada is more than fair in offering to accept Buy America to encompass Canada and the United States.

Glenn Bukoski 09/04/2012
We believe the NITC is a significantly important building block upon which Michigan's long term economic future can be built. In the near term, the multi-year project will created thousands of jobs and supply activities for Michigan workers and companies. The waiver of Buy America is "in the public interest" as the successful completion of this project will greatly benefit our state and the national economy.

Anthony Altonaga 09/04/2012
NO, The Funds in which this hwy is constructed from should not This will open the door for any imported material on this project.

Read this carefully

"Since Michigan intends to use the Canadian contribution as the State match on other Federal-aid highway projects"

Ask What % of fed aid is going to be allocated to Michigan

http://www.fhwa.dot.gov/federalaid/projects.pdf

Do not allow the use of Canadian Steel on a US Hwy Project

And Further investigate how much interest MR.MIKE GUTER from URS Has to this project

And Mr. Glenn Bukoski From Michigan department of Transportation Is this going to be a Deal Breaker if we use American steel in the American side of the border.

Have a Nice Day \ God Bless America

Robert Cosgrove 09/04/2012
Since Canada is providing all the funding for this project(either directly or through MI contribution), it may be "in the public interest" to allow the waiver. The "Buy America" provision is to protect and promote American steel makers. Look at the problem of getting welding wire that meets the "Buy America" provisions.

Mark Murray 09/04/2012
The NITC will be bring great long-term value to the US by further expanding trade between the US and Canada. Given this strengthens ties between our two great countries, and the generous decision of the Canadian government to provide financing, it seems appropriate to waive the Buy American provision to allow Canadian steelmakers to participate as well. I support granting a waiver.

sam odeh 09/04/2012
This bridge should have been built a long time ago. But, we in Michigan have been dragging this project for ever. This bridge is desperately need for the area. I support granting a waiver.

Matt Miller 09/04/2012
I do not believe this waiver to be a negetive thing. Canada is willing to take care of the tab for the whole project; and only asks that we agree to use SOME STEEL that is produced in Canada. Taking both the immediate (jobs) and long trem (commerce) bennefits to the economy of the region, and the USA; this sound like a great deal to me. (I wonder if we could get Canada to go ahead and extend the bridge all the way here to Texas?)

Carey Jernigan 09/04/2012
It seems quite reasonable to use steel from both countries. We really need this new bridge to be built as soon as possible.

Stephen Landes 09/04/2012
The NITC is a cooperative project with our number one trading partner. This bridge and the increased trade in BOTH directions will be a major boost to the entire cross-border economy. The FHWA should grant a waiver for this project because of its international management and control -- it is not a completely US project even thought the source of funding is initially Canadian. Over the life of the project substantial funds from US citizens in the form of tolls will be used to repay the Canadians no differently than if Michigan borrowed the money from a Canadian (or German or CHinese) bank.

Regine Beauboeuf 09/04/2012
As the successful implementation of this project is so intricately tied to Michigan’s economic future and as it is mostly funded by Canadian dollars, I support a waiver of this specific federal requirement for the execution of the Detroit River International Crossing infrastructure project.

Ryan Michael Dinkgrave 09/04/2012
The only existing bridge connecting Detroit and Canada is more than 80 years old. If it were to be put out of service for any period of time – whether due to construction or because of a terrorist attack – it would severely impact the economies of both countries and take a particularly harsh toll on employment in southeast Michigan. Thus the need for a modern bridge crossing and the additional capacity it would provide is critical for maintaining existing employment, particularly in the manufacturing sector.

The NITC is an unprecedented opportunity to stimulate economic activity in Michigan and Ontario, a region that is rebounding from an economic crisis that struck it harder than any other on the continent. The new bridge is anticipated to create 10,000 to 15,000 direct construction jobs in addition to the permanent jobs maintaining the bridge and servicing customers.

As a great example of international partnership and in recognition of our shared reliance on safe and efficient trade crossings between the two nations, Canada has offered to provide funds to cover Michigan's portion. In the same spirit of international cooperation, I urge the U.S. Department of Transportation and Federal Highway Administration grant the waiver and allow the use of both American and Canadian steel and iron in the construction of the bridge.

James M. Goss 09/04/2012
It is logical to use both Canadian and American materials for this project, since the effort has been a partnership from the beginning. The NITC will benefit both economies and further strengthen our relationship with America's most important trading partner.

Don O'Connell 09/04/2012
Canada is putting up the funds to build this project, grant the waiver and let the project begin. The economic impact of this project to Michigan and this country far exceeds what might be lost in steel.

Greg Handel 09/04/2012
We need the bridge build at quickly and cost effectively as possible.

Paul L. 09/04/2012
1) Are the quality assurance/control the same for the manufactuer, melting/mixing, heat numbers, chemical composition, manufacturing standards, final coatings, are they to use step certification? 2) There is  no cost data to compare? Estimate of the amount of steel to be waivered? Total to be used on the project? 3) No percentage requirements for how much of steel/iron to be used by which country? 50/50? Why not write it in the contract...whats built on Canadian soil uses Canadian Steel and USA uses USA manufacturing/steel, you could carry this over maintenance (e.g. seismic retrofits, scour, strengthings, additional lanes/bikepaths/ maint walkways etc...) 4) What about entertaining other foregin bids to see if they can get an alternative based waiver  which entails that if the domestic supplied steel is over  25% over cost of a  lower foreign source (say like the Bay Bridge). Maybe just itemize steel items for 25% differential vs the whole contract? 5) What about the administeration of the Buy America/Canadian Requirements in the contract?Tracking invoices, costs, primes, subs, certificate of compliances, verifications. What units are to be used Metric vs English? 6) As a side note, is there any supply issues for either side? shop size capacities? would there be any schedule delays or advantages of using either or both or truly foreign?

J Duncan Crump 09/04/2012
Funding from both countries... iron and steel from both countries... sounds eminently reasonable. I support the waiver.

john papandrea 09/04/2012
The straight forward use of both American made and Canadian made steel with the same specifications on an America to Canada/Canada to America bridge seems reasonable on its face. However, it is unclear to me what the phrase 'Since Michigan intends to use the Canadian contribution as the State match on other Federal-aid highway projects' actually means.Is it a backdoor to skirt requirements on another project? The use of Canadian steel on this joint project between our two great countries should have no effect whatsoever upon the use of American steel/iron on other projects in Michigan.(I'm sure Canada feels strongly about the use of Canadian products on their own infrastructure.) The perpetual excuse of being unable to obtain a product or skill becomes a self-fulfilling prophecy when we continually invent rationale to off-shore/out-source our manufacturing or construction, typically to low wage countries.

Frederick Frank 09/04/2012
NITC is the link between Canada and US. Only makes sense to permit Canadian steel, especially when Canada foots the bill. Support the waiver

basant kukreti 09/05/2012
Yes .It will open new avenue of growth and prosperty for both the countries.If the steel and iron confirming to desired specification is not available then it can be procured out side the America and canada for speedy execution of Project,to achieve the objective envisaged in mission statement

Mike Schwartz 09/05/2012
The waiver should be granted with the provision that ONLY US and Canadian steel may be used.

Pat Fallon 09/05/2012
The use of steel from both countries seems to make common sense, however that is an uncommon thing these days.

David Thiel 09/05/2012
Allow the use of Canadian made products on this project only. A Buy America Act type of analysis should be applied to materials claimed to be Canadian made. For example, mere assemblage of parts/materials from China does not constitute a Canadian made product.

Mark Chenier 09/05/2012
I live in Windsor, Ontario. Traffic from and to the Ambassador bridge has been a problem for a long time. Huron Church (the road that connects to the Ambassador bridge) is not suitable for that kind of traffic (there are 17 stop lights along the road). We have already started construction on a new parkway to the planned DRIC (NITC) bridge. This new bridge is IMPORTANT to both our countries, the state of Michigan and province of Ontario, as well as the whole region. It will improve trade between our countries and improve traffic flow, which will benefit us all tremendously. This project is huge and HUGELY important to us all, in Ontario and Michigan especially.

R.Larsen 09/05/2012
We need this bridge to keep both America & Canada moving forward. Buying American & Canadian products only makes sence to create jobs,jobs,jobs. For both countries.

Birgit M. Klohs 09/05/2012
Canada is our largest tradingpartner. More than $3.4 billion in goods from west Michigan alone cross into Canada each year. The new trade crossing will enhance that trade; and bring world-class logistics capabilities to both countries. With Canada's generous offer of financing, we should grant the waiver and let Canandian firms participate. This is on behalf of the Right Place, economic developemnt organization for the west Michigan region.

RV Rao 09/05/2012
I fully support this exemption to use Canadian steel in addition to US steel for the greater good of Detroit, Michigan and US in general.

Joshua Blumenkopf 09/05/2012
This is an important project for both the U.S. and Canada and we should be grateful that Canada is paying for it. We should definitely buy materials if necessary from our close ally. Anyway protectionist measures such as "Buy America" stifle commerce and are inefficient and wasteful.

Stephen Ormond 09/05/2012
I support the waiver. This project is perhaps the most important economic development infrastructure project the Great Lakes region. Further delay will irreparably harm the region.

David Foltyn 09/05/2012
I fully support this exemption

Stephen Polk 09/05/2012
The economic relationship between Canada and the U.S. will be enhanced with the addition of an new bridge from Detroit to Windsor. I fully support the project as outlined by Governor Snyder.

David Whitney Johnson II 09/05/2012
In the name of unity and common purpose between our two countries I support the additional use of Canadian steel in the building of the new international bridge crossing.

Patrick Fehring 09/05/2012
Please accept my support of the New International Trade Crossing and the "Buy America" waiver allowing the use of American and Canadian steal in the construction of the NITC. This project will have a significant impact on the Michigan economy by adding jobs and facilitating the expansion of trade between our contries.

Dave Breen 09/05/2012
Given the joint effort on this crossing between the US and Canada, it is only fair and logical that both Canadian and US Steel be used in the bridge's construction.

Neil De Koker 09/05/2012
The waiver should specify that only U.S. and Canadian steel may be used to build the bridge. Based on the financing of the bridge, this request for a waiver is fair and I fully support it.

Bob Riney 09/05/2012
This waiver request is fair, reasonable and pragmatic. We have an opportunity for a significant economic partnership between Canada and the U.S that will create distinction for our region. I fully support the project as defined by Governor Snyder.

Luke Bonner 09/05/2012
I support this waiver

Gary Flinn 09/05/2012
Yes, please make sure the waiver requires that only American and Canadian made steel be used on the bridge project.

Trevor Lauer 09/05/2012
I support this request for waiver The NITC will have a positive economic impact on MI and the greater region. Given the unique financing structure being utilized, the use of steel from both countries is a reasonable request that has my support.

Gerald Pfalzer,LMSW 09/06/2012
As a sociasl worker, many of my clients lack the vary jobs and future opportunities this projects offers to my clients. As such, I very much support the granting of this waiver.

Carol Viau 09/06/2012
We need a publicly owned bridge between Canada and the United States not a private monopoly bridge ,. This crucial to both our countries to create a better flow of traffic and hopefully create more jobs on both sides of the border. the congestion on Huron Line with all the street lights is awful and the owner of the bridge thinks we should just elimate lights he has to be kidding. Maybe if we said no truck traffic allowed on huron line as it is a street not a highway the bridge would really be crying then. Please get this bridge built it is so very important to both our countries

Irene Spanos 09/06/2012
On Behalf of L. Brooks Patterson and Oakland County we too support the waiver and Governor Snyder's plan for the second bridge. It's a crucial part of future growth for companies in Oakland County and the region's future economic growth opportunities. It means more sales for Oakland County companies and that translates into new good paying jobs.

We support this waiver.

Frank Rodriguez 09/06/2012
Do what is right for the economy and future of the local, regional private and business sector by approval (Presidential Permit) of the DRIC Project. The goodwill of the public must always be protected over monopoly interests. Both the United States and Canada must continue to strive for the improvement for the quality of life, job creation and improvement of international commerce.

Lewis Walker 09/06/2012
I support the waiver.

Leslie Murphy 09/06/2012
The construction of a new publicly owned bridge is critical to the growth of the economy in southestern Michigan and Canada. I fully support the waiver on the requirements of 23 CFR 635.410, which would allow the use of American and Canadian steel in the crossing's construction. We need to move forward!!

Leo W. Gerard, International President, United Steelworkers 09/06/2012
The United Steelworkers strongly support the use of both American-made iron and steel and Canadian-made iron and steel to build a new bridge crossing over the Detroit river linking Michigan to Windsor, Canada. This New International Trade Crossing (NITC) will create good jobs, inlcuding jobs producing iron and steel in both the U.S. and in Canada. In the U.S. alone, the bridge project is anticipated to create demand for at least 10,000 directly-related jobs and thousands of indirect jobs.

The United Steelworkers has been a long-time and tireless advocate for strong and expanded Buy American laws to ensure that when our taxpayer dollars are spent on infrastructre projects in the U.S. that goods made in the U.S. are used. Yet, in this one-of-a-kind circumstance, we believe the public interest exception is appropriate under the unique circumstances at issue.

The Windsor bridge project will link together two sovereign nations in an international crossing and will be built within the territory of the two nations. It is much-needed, as there now is only one other bridge in the area, which is quite old. Also,this bridge project has a unique financing mechanism where the Government of Canada will be advancing all funds to build the Michigan portion of the bridge at this international crossing and assuming all financing risk. Without such financing, the project could not go forward. The construction of this international crossing serves the public interest because the bridge is much-needed to better move trade between the two nations -- over 30 U.S. states have Canada as their number one export destination, and Canada is the U.S.'s largest trading partner. So, millions of jobs in both countries are dependent on trade between these two countries and the bridge will help to retain and create more trade between the two nations.

Finally, both countries produce world-class iron and steel and have world-class workers (many are USW members)and can meet the most stringent safety and strength standards to ensure the bridge will be safe for generations to come.

Sincerely, Leo W. Gerard International President United Steelworkers

Blue Wilson 09/06/2012
We need this bridge to increase Manufacturing and equally as important Jobs. A BUY AMERICAN BILL, will insure us with a stronger economy it will create jobs and the money will stay here in America and Michigan again,promoting our, Pure Michigan made, our federal government when buying as American procurment percentages. This bridge will promote economic growth but equally as important it will grow manufacturing and JOBS. As well, it will be fair trade.

Lorron James 09/06/2012
Thank you, Governor Snyder. We support your efforts to develop and build this bridge, which will enhance commerce and provide job creation between two great trading partners, Southeast Michigan and Southwest Ontario. James Group International recognizes the importance of this NITC bridge and the benefit it has to the city of Detroit.

Agricultural Leaders of Michigan 09/06/2012
The Agricultural Leaders of Michigan wish to express our support for the Buy America Waiver for the New International Trade Crossing. Building a new international crossing will benefit all sectors of Michigan’s economy, including agriculture, and provide new opportunities for economic growth and development.

Michigan’s agricultural industry is a significant contributor to Michigan’s economy each year and has the capacity to grow. Our export opportunities have increased significantly in the past several years and we expect them to continue growing. In order for us to seize those opportunities, we need reliable access to international markets, and that starts with our ability to cross the U.S. - Canada border.

The Detroit-Windsor trade corridor is already the busiest trade crossing on the U.S. - Canada border. Michigan exports almost one-third of what we produce here and more than 60 percent of all Michigan’s agricultural exports go to Canada. According to the U.S. Department of Agriculture’s Economic Research Service, agricultural exports helped create 14,700 jobs in Michigan in 2010 and exports are expected to grow to more than $2 billion in 2012. A new international crossing between Michigan and Canada is crucial if we want to keep up with this growing demand and open the door to more business opportunities, growth and jobs.

This bridge isn’t just good news for Michigan agriculture. The benefits extend to all sectors of the economy. Building the new bridge is expected to create 10,000 jobs related to construction of the bridge, and support 237,000 jobs in Michigan that depend on trade with Canada in the long term. Using American and Canadian iron and steel will further boost the economic benefits of the project.

Building the New International Trade Crossing is an important step in the right direction for Michigan’s economy, including the agriculture sector. We urge the United States Department of Transportation to act quickly to approve the waiver.

Sincerely, Dave Armstrong, President and CEO GreenStone Farm Credit Services

Ken Nobis President Michigan Milk Producers Association

George House Executive Director Michigan Allied Poultry Industries Inc.

Mike Wenkel Manager Potato Growers of Michigan

Sam Hines Executive Vice President Michigan Pork Producers Association

Jim Byrum President Michigan Agri-Business Association

Jim Zook Executive Director Michigan Corn Growers Association

Andy Johnston, Grand Rapids Area Chamber of Commerce 09/06/2012
On behalf of the Grand Rapids Area Chamber of Commerce, we strongly granting the waiver.

The New International Trade Crossing is a project that will strengthen the relationship between the United States and Canada, the world’s largest trading partners.

The New International Trade Crossing is not only important for state and national economies, but it will also have a tremendous impact on West Michigan.

Ed Wolking, Jr. 09/06/2012
I recall that more than 230,000 Michigan jobs depend on trade with Canada. The New International Trade Crossing (NITC) will help protect and grow those jobs. It is sorely needed to keep our supply chain position competitive with others'.

Canada and the U.S. have the strongest bi-national trade relationship in the world. We depend on one another's resources and talents. We co-invest. It makes good sense to build the bridge with U.S. and Canadian steel.

In many sectors of our bi-national economy, there are examples of Canadian products that have more U.S. content than U.S. products do. Let's get on with the project.

John Emhof 09/06/2012
We need the bridge and this is a great example of international cooperation to get a needed project done. I support the waiver if it stipulates only US and Canadian Steel as long as the proper specifications are met and it is an equitable split between the countries. The waiver should not be used as an excuse to import steel from third party countries.

Rob Dutkiewicz 09/06/2012
I support the Governor in his efforts to build this bridge. The construction of this bridge would further strenghten trade with our most important trading partner, Canada and would provide hundreds of jobs to workers in both Canada and SE Michigan. I support this waiver.

Deb O'Hagan 09/07/2012
So let me get this straight. The government is building a bridge to compete with a private sector company, which is already willing to build the bridge without using public funding from either country. And then we are asking for a waiver so that we do not have to buy American product to build the bridge which will hurt American jobs and American companies. And we are told that funding will be provided by 1) Canada, which is on the record telling it's citizens that they will not use their public money; and 2) using 'free' Federal Money, as if it weren't our money in the first place. As for the construction related jobs, they will be there even if the private company builds it, so that can come off the table as a plus. And to add insult to injury, MI will lose tax receipts because it will now be a government entity. And let's not forget they will have put a private company out of business. I hope that each business owner that is supporting this proposal finds themselves out of business thanks to someone else's pet government project. It's only a matter of time before 'they' come after your business. Crony capitalism and Big Brother - a very dangerous combination.

Steven Reptior 09/07/2012
No government built or subsidized bridge. Let the private sector build it period !!!!!!!! With their owm money. Thats the only way to fiqure out if it is truely necessary and to have it done in an efficient, cost effective manor. NO more foolish government spending of public money. And no more crony captialism. The government isnt doing his job to protect the public!!!!!!! PS....Its not the governments job to build bridges.

Karla Swift 09/07/2012
The Michigan State AFL-CIO supports the New International Trade Crossing and the Buy America waiver.

The New International Trade Crossing will provide secure and efficient transportation routes for Michigan and the United States to allow economic trading with our Northern neighbors. In 2011, the U.S. and Canada shared $597 billion in trade of manufacturing, agriculture, timber and other products.

The current trade relationship between Canada and the United States supports 11 million jobs, of which 8 million are in the United States and 230,000 in Michigan. The NITC will immediately begin creating an estimated 10,000 new jobs. These good jobs in Michigan will serve as a catalyst to sustaining job growth. When completed, NITC will position Michigan to expand as an international trade hub, creating economic growth and additional jobs.

The NITC is an international project, but is financed solely by Canada. The Buy America waiver is justifiably in the best interest of the United States and Canada, as using U.S. and Canadian produced iron and steel will benefit both parties.

The NITC is a unique and timely opportunity to create jobs and expand the economy for Michigan.

Randall M. Sturm 09/07/2012
I support the Governor and his request for a wavier. In any case, NAFTA probably requires that we put the Canadians on the same footing as ourselves, as long as the materials are competitive.

Anyone voicing opinions similar to Ms. O'Hagan (9/7) is regurgitating talking points initiated by the billionaire owner of the current bridge who has been running a disinformation campaign for the past several years to preserve his monopoly.

This bridge is badly needed to eliminate substantial delays resulting from the current lack of modern infrastructure and to facilitate future trade growth benefiting both parties.

Glenn Nelson 09/07/2012
We don't need no stinking bridge (history and studies confirm this), and certainly cannot risk the potential that the taxpayers of Michigan could end up having to pay for some of a new bridge.

Retake Our Gov Supporter 09/08/2012
There are two major flaws in this request that cry out for public redress. Mr. Jorgenson's continued and blatant use of the term/s "advance/d" to define Canada's financial commitment to this project must be called into question. Boiling that down would imply to me that this is a LOAN from Canada and NOT an investment of, or "Free Money From Canada" as he is trying to imply by the tone in his writing. Secondly Mr. Jorgenson clearly states "All of these facts amply demonstrate that granting this waiver request will serve the public interest." However, he fails to site any research which would serve to validate his assertion that his statements are "fact" by any measure of research. A poorly educated public school graduate would know to site at least one reference study that could be used to validate these assertions as fact. Just because this department and Mr. Jorgenson write something down and submit it does not mean it is "fact."

Elaine Samson 09/08/2012
I am completely in favor of a new bridge. I use to travel to up state New York 20 years ago and a new bridge was needed at that time. Just travel taking the bridge to 401 and you will understand the need. You pass business district, university, and residential area. Our return trip would have to be timed to avoid complete gridlock. A new bridge will open trade.

David Zook 09/08/2012
If we can't afford to purchase American produced materials we can't afford the bridge. Deny the waiver.

Clint Hammerle 09/08/2012
WOW!!!!! IF....( and I don't know for sure ) there is a private company WILLING to build the bridge on their own dime. WHY IN THE HELL DOESN'T A BROKE STATE ALLOW IT TO HAPPEN!!!!!!!!!!!!!!!!!

WAIT.....TO GIVE THE STATE MORE POWER OVER THE PEOPLE!!!!!

15000 jobs for what, 3-4 years. Then what? back to the unemployment line, if the current prez is reelected.

I already pay enough taxes, and we ( the people of Michigan ) don't need to pay millions more in up keep for a new bridge.

I'd love for Gov. Snyder to send me the proposed financial projections for the bridge. I'm no math major, but the feds are broke. So getting grant money is not helping the situation either. Add a couple bean counters to the payroll who have the sole purpose of actually finding out how much things cost ( the proverbial 800$ gov't toilet seat).

I BELIEVE THE WAIVER IS FORCED ON THE STATES BY THE FEDERAL GOVERNMENT TO PAY BACK A DEMANDING CHINA FOR THEIR ROLL IN PURCHASING U.S. DEBT.

THERE IS NO WAY ANYONE CAN MAKE ME BELIEVE THAT OUR GOVERNMENT KNEW NOTHING ABOUT CHINA USING MANY DIFFERENT COMPANIES TO PURCHASE OUR DEBT.

yyBungalowbillbo 09/08/2012
Just to make sure I'm hearing this right: 1) There is a private entity already willing to build the bridge. 2) The governor of the State of Michigan is requesting a waiver to use NON US MADE MATERIALS so that we can further benefit the financial condition of the state AFTER we first skip the buy USA expectation. And 3) actually no Michigan taxpeyer dollars will go into the construction of the bridge. And finaly, 4) there will be a free lunch for every one once the bridge is built. Sounds good to me.

Louis Zakar 09/08/2012
No matter how you look at this bridge,who is really pushing this project anyway just to get it done.When you look at NAFTA highway on the web, you will see this big massive plan of highways, plus a new bridge,for this NORTH AMERICAN UNION. It's not just Govern Snyder just pushing this bridge project, just check out those who run NAFTA, North American Union. In there plans to have a new bridge,get the goods sooner to the stores faster,that will come china. would those who read this note, also check out this Bering Sea Tunnel,that they are planning right now. In this tunnel, would come goods from China much faster than on a container ship from China. By doing this,the time of goods from China, would only take about three to four days by rail, over the five to nine days by container ships waiting to be unloaded on the west coast.This would put those ""BIG RETAILERS"" on an fast track, to get there goods faster in the stores. So this new bridge over the Detroit River, would help those big retailers like Walmart AND other companies that use this new bridge. But who is really driving this new bridge, and where is the ""BIG MONEY COMING FROM ANYWAY"". Govern Snyder maybe be just the front man,in this new bridge project,for those who really want a new over the Detroit River.

CHARLES GUERRIERO 09/08/2012
WE CAN NOT AFFORD ANOTHER BRIDGE.

Anna Janek 09/08/2012
I am against the Bridge and North American Union the real reason he is quietly forcing it on us.

Debra McCann 09/09/2012
As a Us citizen and resident of Michigan I approve of trade between Canada and America, But why are the percentages of steel used by each country Not specified. I believe this is a loophole by design. Placing equitable percentages and striking or clarifying the provision "the state match on other federal-aid highway projects..." would better define this project.

Leo Garry, Macomb Twp, MI 09/09/2012
Deb O'Hagan you speak with uncommon wisdom and insight. I don't know how many nails you hit on the head with your comment, but enough to build all the scaffolding needed to paint the Ambassador Bridge. And in addition to your comments the figures from the Mich DOT do not support the need for additional crossing lanes from Ontario to Michigan. Those in favor of the waiver and the NITC have never heard of "if it is too good to be true, etc"

Richard Cupp 09/09/2012
The previous Governor had her "pet project" (Michigan State Police Post in downtown Lansing) in spite of voters and the needs of the Michigan State Police. Apparently, this Governor wants his "pet project" in spite of voters and needs of Michigan residents. Federal $'s our money. Follow the corruption and the money trail. If approved by the voters, every aspect of the project needs to under the srutiny (finances) and under the watchful eye of Michigan residents. Everything has to be in the open of the public. Richard

Bruce Campbell 09/10/2012
I believe the project is an important building block upon which Michigan's long term economic future can be built. The project will created thousands of jobs and supply activities for Michigan workers and companies over several years and provide long-term jobs in the import/export based economy (e.g., automotive). The waiver of Buy America is "in the public interest" as the successful completion of this project will greatly benefit our state and the national economy. In addition, since the legislature determined that there will be no State participation in the project it only makes sense that a waiver be granted. If no State money is expended the State cannot then demand a direct benefit to the State.

Dave Armstrong, President and CEO, GreenStone Farm Credit Services 09/10/2012
I am writing in support of the proposed Buy American Waiver for the New International Trade Crossing (NITC). The NITC will provide an additional border crossing between the United States of America and Canada by way of connecting Detroit, Michigan and Windsor, Ontario.

As the leading financial services provider for Michigan’s agriculture producers, GreenStone Farm Credit Services has a vested interest in the completion of the NITC. Agriculture is Michigan’s second largest industry and provides an annual impact of more than $91 billion to the state’s economy.

Canada is the largest international consumer of Michigan’s agricultural products and plays a large role in the success of agriculture producers throughout the state. Each year, 30 percent of all Michigan farm products are exported to Canada. Our neighboring nation’s impact on our economy is far reaching, with half of everything Michigan sells globally bought in Canada. Additionally, for 35 U.S. states, Canada is the principal export market.

Completing the new bridge will help ensure that Canada, Michigan, and the rest of the U.S. have a secure and viable transportation method to import and export goods for many years to come. The new bridge will create the first freeway-to-freeway connection between Detroit and Windsor, thus keeping traffic moving and reducing costly delays due to congestion. With more than 8,000 trucks currently crossing the Detroit-Windsor border daily and truck traffic expected to increase 128 percent over the next 30 years, timely completion of the NITC is crucial to the continued success of Michigan’s economy.

Because of the substantial impact the NITC will have on the agricultural industry and Michigan’s economy as a whole, I strongly support the approval of the Buy American Waiver by the U.S. Department of Transportation and the timely completion of this project.

Regards, Dave Armstrong President and CEO GreenStone Farm Credit Services

Ben C. Maibach III 09/10/2012
I support.

Derek Dimitriov 09/10/2012
It appears the billionaire and his mob of minions has hijacked the Buy America Waiver public comments as they are trying to hijack Michigan's Constitution to protect their special interest and near monopoly at the border. The new bridge will add much needed security and redundancy at the Detroit/Windsor border. The new bridge would make Michigan a global trade hub. Just look at New York/Niagara, they have multiple crossings with nearly 20 lanes! Build the bridge!

Leanne Silva 09/10/2012
Where are the benefits to Canadians from this project? It doesn't sound like a good deal for Canadians at all. I think Canada should be creating jobs for her own citizens instead.

Tina Holland 09/11/2012
Sounds like another government spin to get more of our money and tax us to death.

Kirk Branson Sr. P.E. 09/11/2012
If Michigan is to move forward in a way that attracts people to live/work/and stay in this State we will need projects like the NITC. Our recovery will be stronger and last longer if we support this bold step by the Governor. I agree with that quote from the movie Field of Dreams, "if we build it, they will come". I say let's build it and watch them come back to Michigan!!!

Paul Brearey 09/11/2012
This seems like a no-brainer to me simply because the majority of the project is being paid for by Canada. The only portion funded by the United States is the toll plaza in Michigan, which will certainly not use anywhere near the amount of steel that the bridge itself will.

This bridge is critical to trade between the US nad Canada, and the Ambassador is located in an obsolete location and is 83 years old. I drive over it daily, and I am amazed it is legally sound considering the poor condition and visible rust and deterioration that is evident, even despite 3 years of continual construction and traffic disruption.

Do we really want to wait until it literally falls into the river before we begin building a new bridge? Let's do the right thing and build this bridge with Canadian and US steel and built it as soon as possible!

Dan Hilsman 09/11/2012
The NITC is an important infrastructure project for the future of Michigan. As a small business owner on the west side of thet state, I support the application and waiver. I deplore the efforts of Moroun to hold the rest of us hostage to protect his monopoly with the Ambassador.

Frank Rodriguez 09/11/2012
The NITC requires continued & full cooperation between the Unites States and Canada. Therefore, I fully support the Buy American Waiver; with the restriction for use of American & Canadian steel-products be used only.

Commonsense 09/11/2012
Canadians: We are NOT responsible for shelling out tax dollars to stimulate America's economy. Where have you seen a single reason we should even want to?

Remember back when America financianced a project that created 10,000 jobs for Canadians? ...Of course not. And it wouldn't happen if we stood waiting for the next sixteen billion years.

Anyone responsible enough to pay their bills could tell you, reality works like this: Either get your half of the money together, or build your own damn bridge.

I'm sure Canadian tax dollars aren't desperately needed for things of actual importance, such as HEALTHCARE or EDUCATION.

Sickening.

Bill Skubik 09/13/2012
I support a 2nd span. A seccond span would accommodate further increases in truck traffic. Business wants a second span. Canada is our biggest trading partner and we need to be more efficient in our trade.

John D 09/13/2012
What is the purpose of the "Buy America" program if there are continued "Waiver" requests for all sorts of products?? Why don't you clarify what percentages of Canadian and American steel will be used?? Also include the percentages of everything else needed for the project. The problem with you "crooks" in Washington is that your well aware that clarification means details and the details will reveal the TRUTH. What is the truth???

Dirk Bloemendaal, Amway Corporation 09/13/2012
Amway Corporation is a large direct selling company based in Ada, Michigan, right outside of Grand Rapids. We have over 4,000 employees, manufacturing products that include personal care, nutritional and cleaning lines. We are an exporter to the world, selling our products to 100 countries and territories. West Michigan depends upon free trade with Canada - one in seven jobs in the West Michigan region is directly tied to trade with Canada, our largest trading partner. Amway strongly supports the New International Trade Crossing as Michigan's future demands it. The Canadian government is putting up $550 million to cover up-front costs (which can then be used to leverage $2.2 billion in federal money to fix Michigan's roads and bridges), meaning this bridge won't cost Michigan citizens a dime. The new Crossing is critical - American trade with Canada rose from $430 billion in 2009 to $525 billion in 2010, and in the corridor, truck traffic is predicted to triple in the next 30 years and passenger traffic double. Trade is key to growing Michigan's economy and improving the lives of Michiganders; this state can't continue to rely upon an 83-year old bridge through the Detroit-Windsor corridor, one that is the same age as the 1929 Ford Trimotor that recently visited Oakland County Airport. Amway strongly supports the waiver for the use of Canadian iron and steel in the Crossing - it's a small trade-off for strong Canadian support for this new bridge, which will greatly benefit both Michigan and Canada. Let's get the Crossing built, make Michigan the center of U.S. trade, and get Michigan back to where it once was - the center of manufacturing for the free world. We can either look forward or backward - Amway votes to look ahead to the future.

Dirk Bloemendaal, Amway Corporation, Government Affairs 09/13/2012
Amway is a large direct sales company based in Ada, Michigan, just outside of Grand Rapids in West Michigan. We have over 4,000 employees in Ada who manufacture products for the world – extensive lines of personal care, nutritional/dietary supplements, and cleaning products, just to name a few. These products are sold by over three million independent distributors in 100 countries and territories around the world. Amway and its employees depend upon trade.

Amway is no different than many other manufacturers based in West Michigan, a region where one in seven jobs is directly dependent upon trade with Canada. Our company relies upon smooth transportation with Canada, Michigan’s largest trading partner. That trade continues to grow – in fact, American trade with Canada increased from $430 billion in 2009 to $525 billion in 2010. Fully a quarter of that trade flows through the Detroit-Windsor corridor.

The corridor is under severe stress. The Ambassador Bridge, built in 1929 (as old as the Ford Trimotor that recently visited the Oakland County airport, by the way), experiences significant and regular back-ups. Further, the customs plazas are woefully deficient and not designed for the loads they’re now handling. In fact, truck traffic is predicted to triple in the next 30 years and passenger traffic double. This is an untenable situation, particularly at a time when the auto suppliers, and many other Michigan manufacturers, rely upon “just in time” systems to keep their factories operating and keep their employees upon the payroll.

The Canadian investment of $550 million, covering Michigan’s share of the Crossing and leveraged against $2.2 billion in matching U.S. federal highway funds, represents a tremendous gesture by our neighbors to the north. This means that Michigan’s citizens won’t pay a dime for a bridge that is estimated to last well over 100 years. Granting a waiver to allow Canadian iron and steel, in addition to American iron and steel, is a small price to pay.

The entire state, and indeed, the entire American Midwest, has a vested interest in ensuring that the workings of the U.S.-Canadian border are as safe, seamless and reliable as possible. Michigan manufacturers must have that assurance – they don’t have it now. At the same time, Amway believes that the New International Bridge Crossing will inject badly needed competition and redundancy into the system that is now absent.

As a company that began in Michigan 53 years ago that continues to invest substantially in its home state, Amway urges that the waiver to allow Canadian steel and iron – as well as that from the U.S. – be granted. Construction of the Crossing will help the state’s manufacturers move product to market, provide badly needed redundancy, inject over $2.2 billion federal highway funds into fixing Michigan’s roads and bridges, provide over 10,000 badly-needed construction jobs and be a powerful, working reminder that “Michigan is back.”

Bob Beaudoin 09/14/2012
I do not support this waiver request or the project. Where is the control to ensure U.S. steel or manpower will be used in this project? We Michigan citizens have been told of the need for the "Snyder Memorial Bridge" is an absolute necessity. Well, truck traffic is significantly reduced from the heydays of the auto industry.

Mathew Wilson, VP National Policy, Canadian Manufacteres & Exporters 09/14/2012
The Detroit/Windsor gateway is the most critical trade corridor that either Canada or the US has. What crosses through that corridor is not simply finished goods for each other’s supermarkets; it is production parts for the auto industry, machinery and equipment for our factories, livestock and other perishables for our food manufacturers. We are not trading with each other; we are building goods together and competing together in our market and globally against foreign competitors. Our competitiveness and millions of jobs in both countries rely on the efficiency of this trade corridor.

However, the current infrastructure cannot support modern trade realities. Today, over only two weeks, Canada and the US will trade as much in only automotive products as Canada and the US traded in all goods in a full year when the Ambassador Bridge was built. While the current infrastructure fills a critical role today, it does not support the full needs of globally competitive and highly integrated manufacturers. Industry has been clear that it needs uninterrupted highway to interstate access between Canada and the US, not the city streets of Windsor and Detroit; dedicated lanes for certified trusted traders to speed crossings and improve efficiencies; and a second option as a contingency in case of emergencies.

This project has been studied and evaluated more than enough over the past several decades and the solution is clear; the proposed NITC is the best option for the economies in both countries. The model of Canada funding the project should not be controversial as previous projects, such as the Blue Water Bridge, where erected under a similar model, but with the US side picking up the costs. Using combined Canadian/US steel and iron for construction also makes sense given that it is a joint Can/AM infrastructure project the primary building materials should come from both countries. This solution also ensures that the NITC will finally move from being a study, into being a reality that supports our economies.

As such, Michigan's request for a waiver of the requirements of 23 CFR 635.410 is fully supported by Canadian and US industry, and the members of Canadian Manufacturers & Exporters.

W. Scott Thurlow, President of Canadian Renewable Fuels Association 09/14/2012
The Detroit/Windsor gateway is the most critical trade corridor that either Canada or the US has.

What crosses through that corridor is not simply finished goods for each other’s supermarkets; it is feed for our animals and components of fuel for our cars. It is the by-products from the production of our fuels, and the chemicals that are important for other manufacturing sectors.

Our competitiveness and millions of jobs in both countries rely on the efficiency of this trade corridor. The current infrastructure cannot support the growing integrated trade between the two countries.

While the current infrastructure fills a critical role today, it does not support the full needs of globally competitive and highly integrated manufacturers. Industry has been clear that it needs uninterrupted highway to interstate access between Canada and the US, not the city streets of Windsor and Detroit; dedicated lanes for certified trusted traders to speed crossings and improve efficiencies; and a second option as a contingency in case of emergencies.

This project has been studied and evaluated more than enough over the past several decades and the solution is clear; the proposed NITC is the best option for the economies in both countries. The model of Canada funding the project should not be controversial as previous projects, such as the Blue Water Bridge, where erected under a similar model, but with the US side picking up the costs.

This solution also ensures that the NITC will finally move from being a study, into being a reality that supports our economies. As such, Michigan's request for a waiver of the requirements of 23 CFR 635.410 is fully supported by the members of Canadian Renewable Fuels Association.

Don Moore, Executive Director, Canadian Transportation Equipment Assoc 09/14/2012
The Canadian Transportation Equipment Association wishes to provide our support to the comments of the Canadian Manufacturers and Exporter, and thus supports Michigan's application for a waiver of the requirements of 23 CFR 635.410.

Richard Paton 09/14/2012
The Chemistry Industry Association of Canada, on behalf of our members, supports the construction of a new bridge between Windsor and Detroit. The Canadian chemistry industry is export-intensive, responsible for $31 billion in exports in 2011, with over 75% of that trade going to the United States. Canada is also a large importer of chemicals, amounting to $43 billion in 2011. Over half of our trade, in both directions, is between Ontario and the United States. We expect that the volume of trade will increase in coming years as the chemical industry grows in both countries. Therefore infrastructure that allows for the smooth, efficient movement of goods between Canada and the United States is critical to maintaining industry competitiveness.

Robert Clark 09/14/2012
Essar Steel Algoma Inc. supports the granting of the waiver. With the funds being supplied by Canada, it is only fair that the steel be sourced from both countries.

Charlie Pryde 09/14/2012
On behalf of Ford Motor Company, we are writing in support of the United States Department of Transportation granting a waiver of the Buy American requirement for the New International Trade Crossing (NITC).

The NITC is a cooperative international project of Canada and the United States. Requiring the project to exclusively purchase American iron and steel is inconsistent with this partnership and is therefore inconsistent with the public interest. Canadian manufactured steel and iron products should be given the same treatment as U.S products. Moreover, by agreement, Canada is financing the construction costs of the NITC, and therefore should receive the economic benefits of that investment.

Ford’s perspective on this project is based on the view that the NITC is critical to competing in the auto industry:

• Michigan and Ontario are central to Ford’s international competitiveness – between the two, Ford employs about 46,000 people, and has 18 major manufacturing facilities. • The combination of these centers of economic growth produces the Ford F-150, Mustang, Edge and Focus – and engines powering a full range of Ford and Lincoln products.

The border crossing plays a key role in Ford’s business operation – on a typical day, 600 trucks carrying components, engines and completed vehicles cross the border between Ontario and Michigan.

If anything were to happen to stop or disrupt traffic for any extended period of time on the Ambassador Bridge, the economic effects for Ford, our suppliers and the hundreds of other businesses that depend on the crossing, would be devastating. The redundancy of a new bridge minimizes the risk of disruption of cross-border traffic. Moreover, there is no direct freeway to freeway connection through the Ambassador Bridge crossing, which often results in unnecessary congestion and delays.

The NITC is also critically important to the region and Michigan. The Ambassador Bridge is the busiest trade crossing on the United States-Canadian border. A recent study by the Center for Automotive Research outlined the significant economic benefits of the NITC, including:

• Jobs from bridge construction: o Approximately 6,000 created in each of the first two years of construction, and 5,100 jobs for each of the final two years of construction.

• Jobs from statewide construction projects resulting from federal match funding: o Average 6,600 jobs created or retained per year for four years.

• Jobs from bridge operations: o Nearly 1,400 permanent jobs created for operation of the new bridge.

• Jobs from new private investment: o 6,800 permanent jobs created.

• Overall economic growth (combined four-year effect on Michigan Economy): o State domestic product increased by $2.2 billion. o Personal income increased by $4.0 billion. o State and local revenue increased by $400 million.

To compete as a world-class community we strongly support the construction of the NITC to improve traffic flow and reduce or eliminate congestion. We also need this crossing to be built expeditiously. For these reasons Ford Motor Company supports the NITC and the U.S. Department of Transportation granting a waiver on the Buy American requirement .

Robert Haas 09/14/2012
Omg, it is so amazing how our politicians can make such an expensive thing out of the. Is why they all lawyers. What is the problem with our steel and labor on this side and Canadian steel and labor on their end. We never stop makeing a big thing from nothing; yes the bridge is needed.

Michael McSweeney, Cement Association of Canada 09/14/2012
Improving critical infrastructure between our two nations must be the highest priority, particulalrly as the manufacturing outlook for our two nations remains highly questionalble.

Not only will this project create and support significant jobs during construction and operation, the jobs supported through improved trade are necessary to our shared economy.

We fully support the project and the Buy American waiver.

Dana Byrne, Cliffs Natural Resources 09/14/2012
Thank you for the opportunity to comment on Michigan's request for a waiver of the requirements of 23 CFR 635.410 in order to permit the use of American and Canadian iron and steel in the construction of the New International Trade Crossing (NITC).

I write today on behalf of Cliffs Natural Resources in support of Michigan’s request for a Buy America waiver. Cliffs Natural Resources is an international mining and natural resources company and the largest producer of iron ore pellets in North America. Cliffs operates seven iron ore mines in North America – five in the United States (including two in Michigan) and two in Canada – with North American production topping 38 million gross tons in 2011. As a major player in the United States, Canada, and internationally, whose business involves transport of millions of tons of raw materials annually, Cliffs understands the importance of promoting free commerce and building infrastructure to ease transportation with an important international trading partner.

Cliffs Natural Resources has been a longtime supporter of the Buy America requirements for federal aid highway and transportation infrastructure projects. It is our firm belief that public infrastructure projects should use domestically sourced iron and steel in order to maximize economic benefits of taxpayer investments. However, as noted in Governor Rick Snyder’s letter of request for a Buy America public interest waiver, the unique circumstances surrounding the financing of the NITC require an innovative arrangement with respect to the applicable procurement requirements.

This Buy America waiver will thus enable the use of the highest quality American and Canadian produced iron and steel for this most important project. By adhering to this requirement, Governor Snyder and Prime Minister Harper are supporting high-wage, family-sustaining jobs provided by domestic manufacturers who produce high-quality steel, as well as the thousands of jobs in the steelmaking supply chain. In the case of the NITC, use of American and Canadian steel will provide mutual economic benefit for the two nations.

In this regard, we urge the U.S. Department of Transportation to grant a public interest waiver in order to allow for the use of U.S. and Canadian iron and steel in the construction of this critical cross-border infrastructure.

Thank you for the opportunity to comment on this important matter.

Sincerely,

Dana W. Byrne Vice President – Government and Public Affairs

Thomas Gibson 09/14/2012
The American Iron and Steel Institute (AISI) strongly supports the unique bilateral agreement between the State of Michigan and the Government of Canada that will enable the construction of a critically needed bridge between the city of Detroit and Windsor, Ontario using iron and steel produced in the United States and Canada. AISI is the principal trade association representing the North American steel industry and represents member companies accounting for more than three quarters of U.S. and North American steelmaking capacity.

Although the proposed the New International Trade Crossing (NITC) will be entirely financed with Canadian funds, the bilateral agreement provides that all iron and steel construction materials are to be of either U.S. or Canadian origin. This key provision represents a compromise on behalf of the Government of Canada, the importance that the State of Michigan places on promoting the use of American steel, and a mutual desire to ensure that the NITC will be constructed with the highest-quality materials.

AISI is a strong supporter of the Buy America regulations of the U.S. Department of Transportation, which ensure that U.S. taxpayer dollars are used to procure American-made iron and steel products for federally-funded transportation projects. Given the unique financing arrangement for the NITC, however, AISI supports the granting of a public interest waiver to allow the use of Canadian as well as U.S. produced iron and steel for this project. Absent this special arrangement, there would be no assurance that this important project would go forward, and no assurance that a bridge financed with non-U.S. funds would be built with only U.S. and Canadian iron and steel.

The construction of this bridge will provide important economic benefits on both sides of the border. A study released by the Center for Automotive Research shows that the NITC would create an estimated 12,000 jobs a year for each of the projected four years of construction, and more than 8,000 permanent jobs once the bridge is fully operational. Easing road congestion, reducing emissions from idling cars and trucks, and facilitating U.S.-Canada trade are three more examples of how the NITC construction under this agreement will benefit the public. The agreement represents the result of over five years of advocacy by the North American steel industry and its major customer groups, and AISI is pleased to lend its support.

Sincerely,

Thomas Gibson President and CEO American Iron and Steel Institute

Todd Collister 09/14/2012
We support this waiver.

As a great example of international partnership and in recognition of our shared reliance on safe and efficient trade crossings between the two nations, Canada has offered to provide funds to cover Michigan's portion. In the same spirit of international cooperation, I urge the U.S. Department of Transportation and Federal Highway Administration grant the waiver and allow the use of both American and Canadian steel and iron in the construction of the bridge.

Canadian Fertilizer Institute 09/14/2012
We are writing to support the proposed Buy American Waiver for the New International Trade Crossing (NITC). The NITC will provide an additional border crossing between the United States of America and Canada by way of connecting Detroit, Michigan and Windsor, Ontario. The Canadian Fertilizer Institute is a trade association representing the manufacturers, distributors and agri-retailers of fertilizer products in Canada.

To help drive the recovery and economic growth of both Canada and the United States, this project must go forward.

Amy Clickner 09/14/2012
The Lake Superior Community Partnership (LSCP) is a private-public partnership in Marquette County, Michigan whose mission is focused on the promotion and advancement of economic and community development. We serve as the Economic Development Corporation and business resource for Marquette County, Michigan. The LSCP is committed to creating jobs, retaining existing business and attracting new businesses to our region. Our members, 700 strong, are committed to this mission through the investment of time and resources.

The State of Michigan is requesting a Buy America Waiver in respect to the New International Trade Crossing. This waiver is necessary to the successful completion of a project that will be an important part of both Canada and the United States’ economic strength and security. Not only is the waiver a good idea economically, the United States is obligated to allow Canada’s steel and iron manufacturers to contribute to the project based on the U.S.-Canada Agreement on Government Procurement.

This Agreement provides permanent and reciprocal commitments under the WTO Agreement on Government Procurement with respect to provincial, territorial, and state procurement. Since the United States will be benefitting from the construction of the NITC, it follows that Canada should receive similar benefits, be it from the addition of jobs to the profits for manufacturers supplying the materials used in the construction of the Crossing.

The Lake Superior Community Partnership strongly supports the Buy America Waiver and urges you to support and take any appropriate action necessary to assist the State of Michigan in moving this forward.

Paul King 09/14/2012
We support a waiver. The second bridge will benefit both economies.

NITL - CITA 09/14/2012
Dear sir or madam:

The National Industrial Transportation League (NITL) and the Canadian Industrial Transportation Association (CITA) broadly represent industry in the United States and Canada with regard to freight transportation policy, law and regulations.

Both NITL and CITA, and their respective members, have been following closely the progress of plans to build the New International Trade Crossing (NITC) between Detroit, MI and Windsor, ON. This is one of the busiest international trade crossings in the world. Other submissions have documented the value of trade between the U.S. and Canada and the impact of Canada- U.S. trade on employment in the two countries; we will not repeat those statistics here. Our two organizations fully support the NITC project.

As global competition intensifies, it is in the interests of the North American economy that all steps be taken to improve the competitiveness of U.S. and Canadian companies.

The NITC is a bi-national project. Funding of $500 million for this project is being supplied by the Canadian government, to be repaid by tolls. Unquestionably, the NITC will make a significant contribution to improving the efficiency of operations at this critically important crossing as well as the quality of life in and around the highways that will be linked when it is completed. Pursuant to Title 23, United States Code, Section 313, subsection (b), NITL and CITA register their support for the State of Michigan’s request for a waiver from the “Buy America” provisions of Section 313 as related to the use of iron and steel in construction of the NITC.

Sincerely,

Bruce Carlton President and CEO National Industrial Transportation League

Robert H. Ballantyne, P.Eng. President Canadian Industrial Transportation

Devin McManus 09/14/2012
A Canadian funded project should include Canadian made material as major components. Capitol Steel Corp supports this waiver.

Ron Watkins 09/14/2012
The NITC is valuable and essential infrastructure for both the United States and Canada. It will greatly improve the efficiency of cross-border shipping, benefitting manufacurers on both sides of this critical border point, both in the Michigan-Ontartio region and in other parts of both countries. There is no doubt that this project is needed, and well-overdue.

The procurement conditions that specify both American and Canadian steel for the bridge are important for the project to proceed, and also to ensure that this major span is constructed with the high-quality, competitive steel that producers in both countries can supply. The full range of steel products necessary for this project can be produced at steel mills in the two countries. In addition to creating thousands of jobs in both countries, domestic sourcing minimizes transportation costs and environmental impacts in the bridge construction process.

The waiver is necessary to achieve these real and symbolic benefits of two strong economic partners collaborating on shared infrastructure. We add our support to the waiver request.

Tim Etherington 09/15/2012
The owner of the current Detroit-Windsor crossing has offered to build a second span and so avoids the need to apply for a waiver from Buy American while still providing all the same job and trade benefits to Americans.

Further, this Buy American waiver application is for a project that is currently subject to a state-wide ballot and therefore may undergo changes to the project's parameters. As such, this Buy American waiver application is for hypothetical project only.

Therefore, the best option is to allow American business to fund and build the second span, avoiding the need to to apply for a Buy American waiver in the first place while still providing Americans the same job and trade benefits.

Jim Keon 09/17/2012
Michigan's request for a waiver of the requirements of 23 CFR 635.410 is fully supported by the Canadian Generic Pharmaceutical Association (CGPA). The Detroit/Windsor gateway is a critical trade corridor for both U.S. headquartered generic pharmaceutical manufacturers who import U.S.-made generic pharmaceuticals to Canada and those manufacturers who export Canadian-made generic pharmaceuticals to the United States. Bottlenecks at the Ambassador Bridge border crossing have been a long frustration for the generic pharmaceutical industry and manufacturers in other industrial sectors. They have been costly for manufacturers on both sides of the border, and traffic demands on this crossing are expected to rise considerably in the coming years. Manufacturers in both Canada and the United States have been clear that it needs uninterrupted highway to interstate access between Canada and the US, and dedicated lanes for certified trusted traders to speed crossings and improve efficiencies. The proposed NITC is the best option for the economies in both countries. It is time to move NITC forward and make the dream of a second Detroit/Windsor border crossing a reality.

Coralee Johnson 09/17/2012
As a US citizen currently living and working in Canada, I fully support the building of this bridge. I see it as a major economic contributor to both sides of the border. A "win-win" for both countries. Why does progress always meet with resistance? I fully support a waiver of Buy American for this project. As Mr. Rodriquez says above: The NITC requires continued & full cooperation between the Unites States and Canada. Therefore, I fully support the Buy American Waiver; with the restriction for use of American & Canadian steel-products be used only.

tom scanlon 09/17/2012
It's not fair or reasonable to expect a bridge between Canada and the US, which both countries are paying for, to have only US steel and iron and be built with only US labor. The fact that their taxpayers are footing the bill for the whole thing, at least in the short term, makes this even more true. The fair way to do this is to use the steel, iron and workers from both countries. By the way, Canadian ironworkers also built the Brooklyn Bridge, the World Trade Center and the Empire State building (yes they did, check it out). So it doesn't make a lot of sense to start waving the flag now over a bridge between Detroit and Windsor. We're talking about Canada, for God's sake, not Iran or North Korea.

Josh Hansen 09/17/2012
The Federal Highway Administration (FHWA) should waive the Buy American provision of CFR 635.410(c)1 for fund-matching purposes with respect to the New International Trade Crossing (NITC) because enforcing it would be inconsistent with the public interest.

The NITC would serve the public interest by enhancing the lateral support that the U.S. and Canada provide to each other. The mutual interest we share is more significant than that of any other nation we do business with—over $1 billion of goods cross the border each day. The construction of the NITC to augment the Ambassador Bridge would make our supply chains more efficient and cut import/export costs for both countries. Delays in the transportation of goods based on vehicular traffic zaps profits on both sides of the border; with projected traffic increases of 128% over the next 30 years, construction of the NITC represents an important public interest initiative.

The lack of the Buy American provision is equitable under the context because the addition of the bridge will substantially benefit both Michigan and the U.S. as a whole. Moreover, the Canadians and private investors would be taking unilateral financial risks simply by commencing the project. In light of the benefit to be conferred on the U.S. and the allocation of risk involved, splitting the difference on who provides the steel should be considered more than fair.

I strongly urge Mr. Mendez to grant the waiver; it would promote the public interest by allowing us to say "yes" to a great deal.

V/R

Gerdau Long Steel North America 09/17/2012
Gerdau Long Steel North America supports the proposed waiver for the New International Trade Crossing (NITC). As a leader in mini-mill steel production and steel recycling in North America, we look forward to supplying high quality steel products through our vertically integrated network of mini-mills and downstream operations. The new crossing will create greater efficiencies further strengthening both countries in future trade. Additionally, as an extensive user of this corridor it would ensure a competitive transportation mode for years to come. Trade is vital between these two economies, so we strongly encourage moving forward with this project followed by a timely completion.

Mike Jackson, Michigan Regional Council of Carpenters 09/17/2012
I fully support the NITC - On behalf of the Michigan Regional Council of Carpenters and our 17,000 members throughout the State of Michigan, I am writing to convey our strong support for the State of Michigan’s application for a “Buy America” waiver for the New International Trade Crossing. We urge the Federal Highway Administration’s approval of this waiver.

While we generally support using exclusively U.S.-made products in federal infrastructure projects, the Michigan Regional Council of Carpenters understands that the NITC project presents a unique situation. Canada is fronting all of the construction costs, so it’s only appropriate that the project uses both American and Canadian steel. The State of Michigan’s application for a Buy America waiver is necessary for that to happen.

Building the NITC is vital to enhancing Michigan’s – and indeed our nation’s — economic strength and security. The existing bridge between Detroit and Windsor is the busiest trade crossing on the U.S.-Canada border, and is the No. 1 traffic bottleneck in the entire Pan-American freeway system, with more than 8,000 trucks crossing the Detroit border each day. The frequent delays caused by traffic jams on the Canadian side are a significant barrier to expanded U.S. manufacturing activity.

The freeway-to-freeway connection provided by the NITC will greatly enhance the economic activity between Michigan and Canada and lead to increased trade. Our domestic automakers will be able to reduce their costs by this increased efficiency, making our domestic cars and trucks more competitive. Building a modern bridge between Detroit and Windsor will also open new global markets for farmers, entrepreneurs and manufacturers; provide additional capacity to meet long-term demands as the economy grows; reduce costs to job providers; and help to establish southeast Michigan as a global transportation hub.

The NITC presents a tremendous opportunity for Michigan, Canada and the United States. The Michigan Regional Council of Carpenters urges FHA’s approval of the State of Michigan’s Buy America waiver.

Robin Lapointe, vice-president, Structal-Bridges, a div. of Canam Group inc. 09/17/2012
As the largest manufacturer of steel bridges in Canada and one of the key player in the United States, Structal-Bridges fully supports the Buy America waiver for the New International Trade Crossing. This new international crossing, which will benefit both the United States and Canada, is crucial to our economies. The current bridge, which serves the busiest crossing between the United States and Canada, is outdated and simply does not meet the current needs of our respective economies. The present situation is totally different from previous projects, such as the new Blue Water Bridge, where the United States took care of the funding. However, the fabrication requirements and split of work for this project were nevertheless shared equally between the United States and Canada. Canada has agreed to support all costs related to the construction of the new bridge. Under the circumstances, the use of steel from our two countries is not only justified but also reasonable.

Jane Clark 09/17/2012
On behalf of the Michigan West Coast Chamber of Commerce (merger of the Holland and Zeeland Chambers), we strongly support the NITC project which will ensure a well functioning border that is critical to our state and region's economic vitality.

Isabelle Des Chênes, FPAC 09/17/2012
The Forest Products Association of Canada supports this waiver.

Detroit International Bridge Company & Canadian Transit Company 09/17/2012
The following is a summary of Detroit International Bridge Company ("DIBC") and Canadian Transit Company's ("CTC") formal comments (submitted under separate cover) regarding the request made, purportedly on behalf of the State of Michigan, for a waiver of the requirements of 23 C.F.R. 635.410 (the “Buy America Requirements”) to permit the use of foreign produced steel and iron in the construction of the proposed New International Trade Crossing (“NITC”) between Detroit, Michigan and Windsor, Ontario.

First, while the Governor of Michigan supports the NITC and seeks the waiver from the Buy America Requirements, the Governor’s request does not represent the will of the people of the State of Michigan. The Michigan Legislature has not authorized the NITC project (and indeed has affirmatively prohibited the Michigan Department of Transportation and Michigan Strategic Fund from participating in the project), much less authorized a request for a waiver of “Buy America” protection for United States iron and steel workers and manufacturers. Moreover, the people of Michigan will be voting on a referendum this November to determine whether the State should be prohibited from building the NITC unless and until it is approved by public referendum. Thus, since the State of Michigan does not currently support the NITC, and given the express opposition of the Michigan Legislature to the NITC, the application has not been properly submitted and should be denied on that basis alone.

Moreover, even were the application properly made, the requested waiver is not in the “public interest,” as required by 23 C.F.R. 635.410(c)(1). DIBC’s current workforce, past construction and engineering work and choice of suppliers for construction materials, including steel, have all favored United States employees and suppliers. Its New Span will provide more than sufficient capacity for all reasonably forecasted traffic between Detroit and Windsor for at least the next 50 years, and will do so using only United States suppliers of iron and steel. In contrast, construction of the NITC would favor Canadian employees and suppliers, a fact underscored by the Governor’s application. In addition, the City of Detroit noted that if the NITC is constructed, it will destroy 56 existing businesses in the Delray neighborhood that employ between 686-920 employees, and will only create 775 new jobs as of 2035, resulting in a “net loss” of approximately 145 jobs. The net loss of jobs is even greater when one considers the loss of existing jobs at the Ambassador Bridge, the Detroit-Windsor Tunnel, and the Blue Water Bridge that will occur due to the diversion of traffic to the NITC.

Finally, the NITC itself is not in the best interests either of the United States or the State of Michigan. The NITC is not needed, will result in an unnecessary misuse of government resources, and appears to be driven by Canadian, not United States, interests. Federal approval of the NITC further would violate the franchise Congress granted to DIBC in 1921, and will directly undermine longstanding Congressional policy to promote and protect the Ambassador Bridge and the New Span. The NITC further violates United States principles of environmental justice.

Juergen Schachler, President and CEO, ArcelorMIttal Dofasco 09/17/2012
ArcelorMittal Dofasco supports public policy efforts to strengthen the global competitiveness and economic activities of North American steel and manufacturing supply chains. Increasing border efficiencies and improving reciprocal government procurement market access between Canada and the U.S. are two public policy initiatives that support such North American supply chain competitiveness and growth.

Canada and the U.S. are each other’s largest trading partners, building products together within integrated supply chains, with over 30 U.S. States having Canada as their number one export destination. Millions of jobs in both the U.S. and Canada depend on the efficient flow of goods back and forth over our respective borders, keeping our integrated supply chain working efficiently and getting U.S. products to Canadian markets.

The New International Trade Crossing (NITC), linking Windsor, Canada with Detroit, Michigan, is critical infrastructure for the Canadian and U.S. economies. We support the governments of Canada and Michigan in recognizing the importance of the NITC, and the Canadian government’s decision to enable the project by financing it. The NITC will support increased supply chain integration and efficiencies at our shared border, and create an estimated 12,000 construction jobs and 8,000 permanent jobs once the bridge is fully operational. In addition, the NITC agreement stipulates that it will use Canadian and U.S. iron and steel in its construction, further increasing economic benefits and jobs in both countries.

As a result, ArcelorMittal Dofasco lends it’s strong support for the NITC, and the granting of a public interest waiver to facilitate the use of Canadian and U.S. iron and steel in the project.

Sincerely,

Juergen Schachler President and CEO, ArcelorMittal Dofasco

Heather King 09/25/2012
Letter available upon request
Brian Masse 09/17/2012
Letter available upon request
Craig Nudelman 09/25/2012
Letter available upon request
Ed Arditti 09/25/2012
Dear sirs,

I wish to oppose Michigan's request for a waiver of the requirements of 23 CFR 635.410 in order to permit the use of American and Canadian steel and iron in the construction of the NITC.

It is my position that it is premature for any decision to be made with respect to the waiver until such time as it is clear that the NITC bridge will actually be built. As of this date, the question is hypothetical considering that the Agreement between Canada and Michigan may not be legally enforceable under its own terms.

At this time as well, there is a referendum on the ballot in Michigan for the People to decide whether a vote is required by the people of Michigan before an international bridge such as NITC can be constructed. Accordingly, at a minimum, no decision should be made until after the vote on the Referendum.

With respect to the question of the "public interest," that precise issue is being dealt with by the Secretary of State with respect to a Presidential Permit for the project. There are very serious issues about whether or not this matter can go forward because it may not be in the "public interest" of the United States. Attached for your information is a copy of the letter that I submitted to the Department of State with respect to the Presidential Permit. Accordingly, until the Secretary of State makes such a decision, then no action should be taken with respect to the waiver.

In any event, the application should be rejected because there are no provisions provided respecting the amount of Canadian steel and iron that can be used in the project. Presumably, based on the fact that Canada is supposedly providing the financing for the project, the reasonable expectation is that Canadians steel and iron primarily would be used. There is nothing in the waiver request that would prevent that from happening.

In fact, "Michigan asserts that it is unlikely the project will move forward without the ability to use both American and Canadian steel."

I would submit that Michigan has not provided any proof that this statement is true other than making bald assertions.

In addition, there is no definition as to what "Canadian steel and iron means." Could steel be imported from China as an example, be "treated" in Canada and then admitted into the United States as if it was Canadian steel. Since the project is under the control of the Canadian Authority and a P3 operator with minimal involvement by the State of Michigan, there are no checks and balances built in to protect the public interest of the United States.

With respect, that is not in the public interest of the United States.

Providing such a waiver would also disadvantage the Ambassador Bridge Company which wishes as well to build a second bridge beside its existing crossing. Such a waiver could provide a competitive advantage to the NITC bridge to the disadvantage of an American company.

Accordingly, I respectfully ask that the waiver not be granted.

Ed Arditti BA, LL.B, LL.M 710 Roselawn Drive Windsor, Ontario, Canada N9E 1K5 PH (519) 972-3989 Email: arditti@sympatico.ca

Ann Marie Schneider 09/27/2012
Letter available upon request
Edward Wytkind 10/04/2012
Letter available upon request
Bob King 06/06/2012
Letter available upon request
Gary Flinn 10/17/2012
In my rebuttal to Ed Arditti's comment, the NITC bridge WILL be built whether or not Michigan proposal 6 is passed or rejected. The deal was made and construction of the NITC bridge is expected to begin in the spring. On the Canadian side, the Windsor-Essex Parkway is already under construction to connect the NITC bridge to Ontario Highway 401. The NITC will be expressway to expressway, unlike the Ambassador Bridge which has more than a dozen traffic lights on Huron Church Road in Windsor, Ontario between the 83-year-old Ambassador Bridge and Highwary 401.

Meghan Elizabeth 11/11/2012
To whom it concerns. Please disregard any comments from Ed Arditti. He is linked to the Ambassador Bridge Corporation (DIBC) and Matty Moroun its owner. To learn more follow this connection please follow the link provided. http://bit.ly/EdArditti

Contact

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