Letters to Washington

Comments to U.S. Army Corps of Engineers on Draft National Ordinary High Water Mark Manual

The National Stone, Sand & Gravel Association (NSSGA) appreciates the opportunity to comment on the U.S. Army Corps of Engineers (Corps) Draft National Ordinary High-Water Mark (OHWM) Manual (manual). NSSGA applauds this extensive compilation of science but is concerned about the lack of clarity about when it should and should not be used. We are especially concerned that it could expand the jurisdictional reach, in conflict with the Supreme Court’s unanimous Sackett ruling and could limit the use of Nationwide Permits (NWPs).

Comments to Congress on the Proposed EPA Particulate Matter Standard

On behalf of the National Stone, Sand & Gravel Association (NSSGA), the National Ready Mixed Concrete Association (NRMCA) and the Portland Cement Association (PCA), we write to you today regarding our deep concern over the proposed Environmental Protection Agency (EPA) particulate matter (PM) standard that is expected to lower the National Ambient Air Quality Standard (NAAQS) particulate matter standard (PM 2.5) from its current level of 12.0 micrograms per cubic meter of air (µg/m3) to within the range of 8.0 to 11.0 µg/m3.

Comments to EPA Regarding the Proposal for Revisions to Air Emissions Reporting Requirements

The National Stone, Sand & Gravel Association (NSSGA) respectfully submits these comments regarding the proposal for Revisions to Air Emissions Reporting Requirements (AERR). NSSGA is also a part of the AERR coalition and incorporates those comments by reference. NSSGA urges the U.S. Environmental Protection Agency (EPA) to reconsider this proposal. It will create great hardship for non-major sources under the Clean Air Act (CAA) like aggregates and not provide accurate data for the National Emissions Inventory (NEI).

Coalition for Workplace Safety Comments to DOL on OSHA's Proposed Rulemaking Regarding the Worker Walkaround Representative Designation Process

These comments are submitted on behalf of the Coalition for Workplace Safety (“CWS”) and the 74 undersigned organizations (“the Commenters”), pursuant to the Occupational Safety and Health Administration’s Notice of Proposed Rulemaking regarding the Worker Walkaround Representative Designation Process under the OSH Act, 88 Fed. Reg. 59825 (Aug. 30, 2023) (“Proposed Rule”). For the reasons outlined below, the Commenters urge OSHA to withdraw the proposed rule entirely.

Letter to DOL Regarding Proposal to Raise Salary Threshold for Executive, Administrative, Professional, Outside Sales, and Computer Employees Exemptions from Overtime Requirements

The National Stone, Stand & Gravel Association (NSSGA) submits these comments on the Department of Labor’s (DOL or the Department) proposal to raise the salary threshold for the executive, administrative, professional, outside sales, and computer employee exemptions from the overtime requirements of the Fair Labor Standards Act (FLSA). NSSGA represents the aggregates and industrial sand industry, with over 9,000 facilities and more than 100,000 employees in high-paying jobs. As a signatory, NSSGA strongly supports the comments filed by the Partnership to Protect Workplace Opportunity (P

Comments to STB on Proposed Rulemaking in "Reciprocal Switching for Inadequate Service"

National Stone, Sand & Gravel Association (NSSGA) submits these comments in response to the Surface Transportation Board’s (STB or the Board) Notice of Proposed Rulemaking (NPRM) in “Reciprocal Switching for Inadequate Service,” which focuses on providing rail customers with access to reciprocal switching as a remedy for poor service, based around three measures of carrier success or failure, namely: (1) service reliability; (2) service consistency; and, (3) adequacy of local service. NSSGA is the leading voice and advocate for the aggregates industry. NSSGA members use freight rail to

Coalition Letter to Senate and House Armed Services Committees on Material Neutrality in NDAA

On behalf of the American Concrete Pipe Association (ACPA), Copper Development Association Inc. (CDA), Ductile Iron Pipe Research Association (DIPRA), National Ready Mixed Concrete Association (NRMCA), National Stone, Sand & Gravel Association (NSSGA), and the Steel Tank Institute/Steel Plate Fabricators Association (STI/SPFA), we are concerned about continued efforts in Washington to pass legislation that prefers specific materials at the expense of proven materials.

Industry Letter to White House on Maintaining Existing National Ambient Air Quality Standards for Fine Particulate Matter (PM2.5)

The undersigned associations urge you to ensure the Environmental Protection Agency maintains existing National Ambient Air Quality Standards for fine particulate matter (PM2.5). A proposed discretionary revision to this standard, which is under review by the Office of Information and Regulatory Affairs, could put nearly 40% of the U.S. population in areas of nonattainment. Doing so would risk jobs and livelihoods by making it even more difficult to obtain permits for new factories, facilities and infrastructure to power economic growth.

Comments to Financial Accounting Standards Board on Proposed Accounting Standards Update

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comments in response to the Financial Accounting Standards Board’s (FASB) Exposure Draft, Proposed Accounting Standards Update: Income Statement – Reporting Comprehensive Income-Expense Disaggregation Disclosures (Subtopic 220-40) – Disaggregation of Income Statement Expenses. NSSGA members consist of stone, sand and gravel producers; industrial sand suppliers; and the equipment manufacturers and service providers who support them. 

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