Comments to OMB RE: Request for Comments on Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis
The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comments in response to the Office of Management and Budget’s (“OMB”) Aug. 2, 2023, “Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis” (Draft Guidance). Our industry is heavily regulated from federal, state, and local entities. These regulations are ever changing, and many times are contradictory, causing significant delay and expense for approving projects. Our industry is facing greater regulatory uncertainty, as federal agencies work to implement a vast array of costly and complex permitting changes that will place new burdens and complicate our ability to access and supply materials. We strongly encourage OMB to use the greatest flexibility possible when considering how regulatory changes impact industry.