The National Stone, Sand and Gravel Association (NSSGA) is pleased to submit these comments on proposed U.S. Fish and Wildlife Services (FWS), National Marine Fisheries Service and National Oceanic and Atmospheric Administration (the agencies) Listing Endangered and Threatened Species and Designating Critical Habitat; Implementing Changes to the Regulations for Designating Critical Habitat under the Endangered Species Act (ESA). In general, NSSGA finds much of the proposed changes unjustifiably add to confusion and the scope of the ESA.

The National Stone, Sand and Gravel Association (NSSGA) is pleased to submit these comments on proposed U.S. Fish and Wildlife Services (FWS) Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants, under the Endangered Species Act (ESA). In general, NSSGA finds the proposed changes unjustifiably expand the scope of the ESA.

On behalf of the 450 members of the National Stone, Sand & Gravel Association (NSSGA), we express our support for the Promoting Local Management of the Lesser Prairie Chicken Act and extend our gratitude for reintroducing this critical legislation. We firmly believe that the U.S. Fish and Wildlife Service (FWS) should be held accountable for their irresponsible efforts in relisting the Lesser Prairie Chicken as an endangered species.

On behalf of the 450 members of the National Stone, Sand & Gravel Association (NSSGA), we write to urge you to vote to reverse the U.S. Fish and Wildlife Service’s (FWS) designation of the Northern Long-Eared Bat (NLEB) as endangered under the Endangered Species Act (ESA), on S.J. Res 24 and H.J. Res. 49.

On behalf of the 400 members of the National Stone, Sand and Gravel Association, we appreciate the opportunity to provide feedback and response to the EPA’s RFI to support new IRA programs to lower embodied greenhouse gas emissions with construction materials and products. NSSGA is the leading voice and advocate for the aggregates industry and the businesses that supply them, with member companies representing more than 90 percent of the crushed stone and 70 percent of the sand and gravel consumed annually in the United States.

The undersigned associations (collectively, the “Coalition”) offer the following comments in response to the Council on Environmental Quality’s (CEQ’s) Interim National Environmental Policy Act (NEPA) Guidance on Consideration of Greenhouse Gas Emissions and Climate Change (“Interim Guidance”). Our organizations represent a diverse set of economic sectors that form the backbone of the American economy—agriculture, energy, construction, mining, forestry, manufacturing, transportation, and other sectors.

The National Stone, Sand & Gravel Association (NSSGA) appreciates the opportunity to comment on the U.S. Environmental Protection Agency (EPA) reconsideration proposal for the National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM).  NSSGA is a member of both the Coarse Particulate Matter Coalition (CMPC) and the NAAQS Regulatory Review & Rulemaking (NR3) Coalition, and incorporates their comments by reference.  NSSGA supports the proposal for retention of the current standard for PM10, but opposes the reduction of the PM2.5 standard. 

We represent construction materials vital to our nation’s infrastructure and are providing comments regarding the proposal by the U.S. Environmental Protection Agency (EPA) for Reconsideration of the National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM).  Our organizations represent hundreds of thousands of employees across the country and include the National Stone, Sand & Gravel Association (NSSGA), National Asphalt Pavement Association (NAPA), National Ready Mixed Concrete Association (NRMCA), and the Portland Cement Association (PCA) (associations).

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.

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.