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EPA

Division of Dockets Management

1616 North Ft. Myer Drive

Arlington, VA 22209

Re: Federal Register  August 31, 2004 (Vol. 69, No. 168)

Docket No. DHS 2004-0002

RIN 1615-AA00

To Whom It May Concern:

The Detroit Windsor Tunnel (Tunnel) is the busiest passenger border
crossing on the U.S. Canadian Border. The Tunnel is typical of those at
the other major crossings between Ontario, Michigan and New York,
although we remain unique as the only vehicular tunnel crossing in the
U.S.

> Our goal is to work with the Department of Homeland Security
> (Department) to ensure the smooth implementation of US VISIT on both
> outbound and inbound traffic. While we support the implementation of
> the US VISIT program at land border crossings as an effective
> mechanism to enhance national security and facilitate legitimate trade
> and travel, we remain concerned about implementing the U.S. VISIT
> program and requisite technology at the land border. More
> specifically, we remain concerned about the unique infrastructure to
> accommodate the added technology at the Detroit Windsor Tunnel.

Today's land border crossings were neither designed nor built to meet
the security and technology needs in the post 9.11 environment. Though
the entry portion of US VISIT has been implemented successfully,
foreseen requirements for the 'exit' portion remain a concern. US VISIT
is going to require dedicated space at the crossings, to enable the DHS
to properly process those leaving the country, which will take time and
disrupt traffic on our plazas. In implementing US VISIT at the Tunnel,
we are concerned about the following issues:

-   As an urban border crossing with a fixed plaza footprint there is
    extremely limited space for vehicles to park if people, belongings
    or vehicles need to be inspected further. Furthermore, inspectors
    park their personal vehicles on the Tunnel's plaza further limiting
    space for passengers at the Tunnel. How will the program accommodate
    this anticipated need?

-   The system as described in the Federal Regulations will require
    mounting federal equipment in areas traditionally reserved for the
    operator. Additionally, the system appears that it will require
    continual presence by CBP inspectors. There are some critical
    infrastructure, safety, staffing, management and process issues that
    will need to be addressed.

In addition, while we understand that it takes on average approximately
15 additional seconds during inspection at airports; it is a different
situation at land borders. As opposed to people walking off planes to
visit a kiosk or enter a processing area, individuals arriving at land
borders in need of additional US VISIT support or scrutiny must park
their vehicles and cross in bound and out bound tunnel traffic to get to
the controlled CBP processing area. With over 16.5 million vehicles
passing through the Tunnel each year and 5,000 commuters each day, what
is the Department's plan for moving pedestrians at the Tunnel?

As to staffing, does the Department plan on placing CBP officers in
Tunnel tollbooths for outbound traffic or will certain technology be
used? And if technology is used, how will the Department handle a
situation in which a car needs to be inspected further? How will
vehicles be pulled over and where will they park? And what kind of
technology will be needed in the Tunnel's toll booth area?

Furthermore, many travelers are hesitant to cross the border because
there is confusion as to what they need to bring to the border. We
encourage the Department to make sure the operators have enough
information to share with their customers about the US VISIT process, in
addition to implementing a comprehensive marketing campaign to educate
those that will be affected by US VISIT.

In regards to specific needs at the border, we are curious as to
Department's plans for signage at the Tunnel and in what languages the
signs be in. We have visitors from many different backgrounds visit us
at the Tunnel. Therefore, the easier information is given to people
before they arrive at the Tunnel the less confusion travelers will have
and the more seamless the border will appear.

Another concern we have is how US VISIT will work with the rest of the
border. For example, how will US VISIT be integrated with ACE, FAST,
NEXUS, C-TPAT and other programs and will there be enough flexibility to
accommodate new programs not yet envisioned. Likewise, how much room
will US VISIT and other Department programs take up in regards to
technological infrastructure? And will there be money in the
Department's budget to accommodate these changes.

As the Department begins to implement US VISIT at the land border, we
recommend that you implement it strategically, rather than speedily in
an effort to meet the recommendations from the 9.11 Commission. We hope
that the Department will not implement US VISIT at the land border
without guaranteeing it will not add to disruption of traffic at the
border.

As operators of the busiest passenger border crossing on the U.S. Canada
border, we want to work with you in implementing US VISIT and other
programs at the border. But before we can help we must know what your
needs are and how they can best fit into the individual footprint of
each crossing. We welcomed the opportunity to meet with officials from
US VISIT, and look forward to continuing that dialogue and partnership.
We also recommend that the Department organizing briefing materials from
implementing US VISIT from an operators perspective so that border
operators know what to expect and how to work with the Department in
implementing US VISIT and other important programs. The Detroit and
Canada Tunnel Corporation would be proud to collaborate with the
Department on this project.

However, in regards to communicating the Department's needs and programs
at the border, we encourage the Department to make sure their local
representatives are briefed on these issues and timelines as to minimize
internal confusion and all the key border stakeholders can become aware
of these programs.

Finally, we understand that since most Canadian citizens are visa
exempt, they are currently not subject to the US-VISIT process. We hope
that this remains the case as a good percentage of those who cross our
facilities are either low-risk Canadian nurses working in Detroit based
hospitals or other Canadians who work in the region.

The Detroit and Canada Tunnel Corporation fully supports the goals of US
VISIT, which is improve public safety, national security and the
integrity of the immigration process. We are eager to work with the
Department in implementing US VISIT and we looking forward to working
with you. We are also committed to helping the Department achieve its
goals of modernizing our borders, harmonizing our systems and creating a
better, faster, more secure border. The Detroit Windsor Tunnel remains
available to the Department of Homeland Security and others to expand on
our concerns and how we feel the program could be implemented to
maximize national security and minimize disruption.

We support the Department and the President in ensuring that border
security enhancements do not adversely affect legitimate travel and
trade. In fact, we would like to actively help in making that happen.

Please feel free to contact me or Daniel Cherrin at t. 248.540.9660 x
375 / <dcherrin@public-i.com>, with any questions or concerns.

Yours truly,

Neal Belitsky

Neal Belitsky

Executive Vice President and General Manager

cc\. Sens. Levin, Stabenow; Reps. Knollenberg, Kilpatrick, Dingell,
Camp; State of Michigan -- DC Office, CBP-Detroit

dc/NB