Letters to Washington

Letter to Surface Transportation Board on STB's Notice of Proposed Rulemaking in “Reciprocal Switching for Inadequate Service” Board Action

National Stone, Sand & Gravel Association (NSSGA) submits these Reply Comments in response to the Surface Transportation Board’s (STB or the Board) Notice of Proposed Rulemaking (NPRM) in “Reciprocal Switching for Inadequate Service,” Board action that 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.

Letter to Bureau of Land Management on the Proposed Placitas Withdrawal

On behalf of the over 400 members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to express our opposition to the proposed Placitas Withdrawal, that would permanently ban future aggregate production in areas of central New Mexico, severely limiting critical resources needed in the construction of infrastructure and public works projects for this growing region. NSSGA represents aggregates producers and those who manufacture equipment and services that support the construction industry.

WAC Letter to Corps on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams

The Waters Advocacy Coalition (“WAC” or “Coalition”) offers the following comments on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams (“Draft Manual”). WAC represents a large cross-section of America’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving economy and provide much-needed jobs.

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.

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

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

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.

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