The organizations signed below collectively submit the following comments on the Office of Management and Budget’s (OMB) proposed amendment to 2 CFR 184 and 200, and responses to questions outlined in the preamble of the notice of the proposed rule. We divide our comments into three sections: 1) Authorities contained in the Build America, Buy America Act (BABAA) provisions of the Infrastructure Investment and Jobs Act (IIJA) pertinent to our construction materials; 2) Responses to questions in the preamble; and 3) Additions and strikes required by BABAA to the proposed rule.
Coalition Letter to Budget Committee and Ways and Means Committee on the Biden Administration's Proposed Budget
The budget released today continues the Biden administration’s attack on individually- and family-owned businesses and should be strongly opposed by Congress. The more than $4 trillion in tax hikes it proposes target businesses responsible for most of the jobs and growth in this country and come at a time when federal tax collections are at record levels. The President claims his budget will only go after “super-wealthy” tax cheats, but it targets over one million small and family-owned businesses.
The diverse group of construction and business associations undersigned urge the U.S. Department of Commerce to ensure public investments in the semiconductor industry are not needlessly constrained by anti-competitive and inflationary policies imposed through unlawful regulatory action. The Creating Helpful Incentives to Produce Semiconductors and Science Act provides $39 billion in federal grants, loans and loan guarantees to rebuild America’s semiconductor manufacturing capacities and allows companies a 25% advanced manufacturing investment tax credit.
The undersigned associations urge you to support the “Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023.” The BUILDER Act would reduce permitting delays and create more certainty from the beginning of an agency environmental review through any potential judicial review. Investments in renewable energy and lower emissions technologies, critical mineral mining, and forestry to transportation projects are taking four to ten years to complete permitting. These delays serve only to impede critical improvements now and in the future.
Support for S.J. Res. 7, the CRA Resolution of Disapproval of the Biden Administration’s New WOTUS Rule
On behalf of the 400 members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to share our strong support for S.J. Res. 7, the Congressional Review Act (CRA) resolution of disapproval on the Biden administration’s new Waters of the United States (WOTUS) Rule. NSSGA urges every member of Congress to support this measure, which will bring immediate and needed permitting certainty, as the aggregates industry works to deliver materials to build our infrastructure.
Letter to House T&I and EPW Committee Leadership Supporting H.J. Res. 27, the CRA Resolution of Disapproval on the Biden administration's new WOTUS Rule
On behalf of the 400 members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to share our strong support for H.J. Res. 27, the Congressional Review Act (CRA) resolution of disapproval on the Biden administration’s new Waters of the United States (WOTUS) Rule. NSSGA urges every member of Congress to support this measure, which will bring immediate and needed permitting certainty, as the aggregates industry works to deliver materials to build our infrastructure.
Water Advocacy Coalition Letter Supporting the CRA Resolution of Disapproval on the Biden Administration's New WOTUS Rule
As organizations representing a broad range of sectors from agriculture, energy, transportation infrastructure, construction and real estate, manufacturing, mining, recreation, chemical production, state departments of agriculture, and many other job creators, we urge support for the Congressional Review Act resolutions of disapproval of the Environmental Protection Agency (EPA) and the Army Corps of Engineers (Corps) 2023 revised Waters of the United States (WOTUS) regulation. Every sector of the U.S.
The National Sand, Stone and Gravel Association (“NSSGA”) appreciates the opportunity to provide this comment letter on the proposed revision of the Federal Acquisition Rules (FAR) to implement section 5(b)(i) of Executive Order (E.O.) 14030, Climate-Related Financial Risk, to require major Federal suppliers to publicly disclose greenhouse gas (GHG) emissions and climate-related financial risk and to set science-based reduction targets. NSSGA represents aggregates producers, as well as those who manufacture equipment and provide services that support the construction industry.
On January 25th, 2023, the General Service Administration (GSA) released for comment the GSA developed minimum requirement standards for Inflation Reduction Act (IRA) funded purchases of materials and products with substantially lower embodied carbon based on, and in accordance with, EPA’s Determination under Section 60503 of IRA. The National Sand, Stone and Gravel Association (NSSGA) appreciate the opportunity to comment on the GSA developed standards to promote the procurement of materials and products available today with the comparatively lower embodied carbon.
The diverse group of construction and business associations undersigned writes in strong support of the Fair and Open Competition Act––to be introduced by Rep. James Comer, R-Ky., and Sen. Todd Young, R-Ind.––and asks you to become an original co-sponsor of this important legislation. The Fair and Open Competition Act would prevent federal agencies and recipients of federal assistance from requiring or encouraging contractors to sign a controversial project labor agreement as a condition of winning a federal or federally assisted, taxpayer-funded construction contract.