Not necessarily because no one lives underground and there are probably no existing things like property, gas lines, electricity lines, sewers, pipelines, roads, etc to avoid or reroute. And very little in the way of habitat.
The longest road tunnel in the world only cost about 100 million in the 90s for 25km so tunneling isn't always a gigantic Big Dig style clusterfuck.
In terms of legal complexity, it's fantastically easier than picking your way across and near thousands of individual plots of very expensive land owned by people with solicitors salivating at the potential fees, expensive private infrastructure, nature reserves and so on.
> Big Dig style clusterfuck.
The big dig is probably the last major success of American infrastructure. Referring to it as a clusterfuck is representative of why we'll never get another one.
> The longest road tunnel in the world only cost about 100 million in the 90s for 25km so tunneling isn't always a gigantic Big Dig style clusterfuck.
Big Dig style clusterfuck is because the simplicity and cheapness you're talking about only apply to tunnels through mountains, less so to those underwater and definitely not to tunnels under big cities i.e. land that people live on, which comes with all the complexity.