Based on the foregoing assumptions, if the restrictions were lifted, miles driven on Michigan roads by commercial motor vehicles carrying hazardous materials would decrease by 98,665 miles to 119,100 miles annually. Miles driven by commercial motor vehicles carrying hazardous materials through the Delray neighborhood on their way to the Detroit-Windsor Ferry would decrease by 14,040 to 17,550 miles. (Ex. 5,

Calculations).

Since November 1, 2010 to September 1, 2020, there have been 29 accidents involving hazardous materials on I-94 between Ramp 190A and the Blue Water Bridge. Fourteen of those 29 accidents involved Class 3 or Class 8 hazardous materials. (Ex. 6, Michigan State Police data).

The foregoing analysis demonstrates that lifting the restrictions as requested by DIBC would decrease the number of miles driven by commercial motor vehicles carrying hazardous material on Michigan roads and thus would increase safety on Michigan roads. In short, lifting the restrictions on Class 3 and Class 8 hazardous materials on the Ambassador Bridge will result in less risk to the public. This provides a basis for MDOT to make a •nding that the proposed changes enhance public safety in the areas subject to its jurisdiction and in other areas which are directly affected by the routing designations in question.

Describe the DIBC’s •re suppression system and the design standard relating to the National Fire Protection Association WFPA) 502 (Standard for Road Tunnels, Bridges and other Limited Access Highways).

DIBC’s •re suppression system is a “dry line” system where vertical standpipes are located along the bridge perimeter with Siamese connections at ground and roadway level. The standpipes on the Detroit side of the bridge can be connected directly by hoses to nearby hydrants or Detroit Fire Department pumping equipment. The standpipes on the

Windsor side of the bridge can be connected directly by hoses to nearby hydrants or

Windsor Fire Department pumping equipment. Photos depicting the foregoing are attached as Ex. 7.

On the Windsor side of the Ambassador Bridge, the Windsor Fire Department has con•rmed that the •re suppression system has been installed in conformance with NFPA 502. (Ex. 8, July 8, 2020 letter from the Windsor Fire Department). According to the

Windsor Fire Department, “[t]he system is comprised of three dry pipe risers located on the Canadian side of the Bridge starting at ground and terminating at the bridge roadway with a Siamese connection at both ends equipped with Canadian thread design. All three risers are located in close proximity to a municipal •re hydrant with gate access to the rlser.”

The Detroit City Code promulgates the “Detroit Fire Prevention and Protection Code”

(the “Code”). Chapter 18, Art. 1, Sec. 18-1-1. The Code incorporates the “National Fire Protection Association 1, Fire Code, 2015 Edition”. See. 18-1—21(a). “The Code shall be administered and enforced by the authority having jurisdiction, who is de•ned in Section 2—1 of this Code, as the Fire Marshal of the City”. Sec. 18-1-22. “The Fire Marshal has