Letters to Washington
| November 17, 2023

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). There are many unintended consequences to making such a large number of businesses, many very small, subject to proving a negative – that they do not exceed the very low limits for nearly 200 hazardous air pollutants (HAPs). This proposal adds significant burdens without a proven need. Should EPA move forward with this proposal, NSSGA urges EPA to exempt the aggregates industry due to (1) the low HAPs emissions, (2) the lack of any processes that process and/or produce HAPs for sale, (3) the facility locations distant from communities, and (4) the large number of small entities in the aggregates industry.