Comments to Army Corps of Engineers on their Proposal To Reissue and Modify Nationwide Permits
The National Stone, Sand and Gravel Association (NSSGA), is pleased to submit these comments on the Army Corps (Corps) of Engineers’ proposal to reissue and modify nationwide permits (NWPs). NSSGA supports this reissuance but continues to believe the size limits are too small and that aggregates should have its own permit, separate from other mining. NSSGA is the leading advocate for the aggregates industry. Our members are responsible for the essential stone, sand and gravel found in road and public works projects as well as erosion control, wastewater, sewage, air pollution control, and drinking water purification systems. Aggregate companies take rock from the ground, then crush and sort it. When aggregate producers are finished using the stone, sand, or gravel in the area, they return the land to other productive uses such as drinking water reservoirs and nature preserves. The determination of CWA jurisdiction is critical to this industry, and NSSGA has provided input and comments on every major WOTUS action undertaken by the agencies. The scope and reach of CWA jurisdiction have a direct impact on the costs of planning, financing, constructing, and operating an aggregates facility.