Advocating for Regulatory Reform

This week, NSSGA submitted comments on behalf of the aggregates industry to support important Environmental Protection Agency (EPA) reforms that should improve EPA’s regulations and requirements that NSSGA members must comply with. The reforms include withdrawing the damaging 2015 Waters of the U.S. Rule, standardizing the cost benefit analysis process for rulemaking and improving the quality of science that underpins many EPA actions.

On Aug.13, NSSGA and several member companies submitted comments supporting the delay and withdrawal of the damaging 2015 Waters of the U.S. Rule. NSSGA has long opposed the rule, which would have required costly and prolonged federal permits for disturbing dry land and other unreasonable requirements, including litigation. As EPA works to withdraw and replace the 2015 rule, they have delayed the implementation of the 2015 rule. EPA proposed a supplemental rule to bolster the legal defense of these actions, and NSSGA provided comments supporting this rule, as well as the negative effects of the 2015 rule.

Also, on Aug. 13, NSSGA provided support for EPA’s efforts to improve consistency in cost benefit analysis that the agency completes for many rulemakings and other requirements. NSSGA noted that in the past EPA has used improper methods to demonstrate that benefits outweigh the costs, as they did in the WOTUS rulemaking.

NSSGA commented Aug. 16 in support of EPA’s proposal that requires the agency to modernize its rulemaking process. An updated process will help ensure that the research methods and findings that EPA relies on to support its technical regulations will pass rigorous scientific and legal review. Currently, independent scientists cannot validate all of EPA’s research findings when the underlying methods and data are not made publicly accessible. This proposal goes a long way towards fixing that problem, while accommodating the need to protect important privacy interests.

“NSSGA will continue to voice it’s support for streamlined and scientifically rigorous requirements on EPA’s actions that affect the aggregates industry,” said Michael W. Johnson, NSSGA president and CEO.

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