The undersigned organizations respectfully urge a comment period extension of at least 45 days on the Council on Environmental Quality’s (“CEQ’s”) proposed rule to amend the procedural provisions of the National Environmental Policy Act (“NEPA”), including the implementation of the Fiscal Responsibility Act’s significant amendments to NEPA. The undersigned organizations represent many sectors of our economy. Our industries drive economic growth, from telecom to ports, airlines to automakers, energy, construction and labor, real estate, mining, trucking, manufacturing and more.

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.

The undersigned organizations representing the Rail Customer Coalition (RCC) urge the renomination of Surface Transportation Board (STB) Chairman Martin Oberman and Member Patrick Fuchs. The RCC is a collection of trade associations representing a broad cross-section of manufacturing, agricultural, energy and other industries that depend on the railroads to deliver reliable and affordable service so our members can remain competitive in the global market. Our members collectively provide more than 7 million jobs and produce more than $4.8 trillion in economic output.

On July 13, 2023, The Mine Safety Health Administration (MSHA) published a proposed rule, “Lowering Miners' Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” (Silica Standard). The Silica Standard provides for a public comment period of 45-days, which expires at midnight eastern time on August 28, 2023. The National Stone Sand & Gravel Association (NSSGA) requests an extension of the public comment period for an additional 60-days and proposes that the public comment period be extended until midnight eastern time on October 27, 2023.

The National Stone, Sand & Gravel Association (NSSGA) strongly urges the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) (the agencies) to immediately issue a public, post-Sackett memo on approved jurisdictional determinations (AJDs) for areas that are clearly excluded from jurisdiction under the Sackett v EPA (Sackett) opinion. While we agree that an updated rule is needed for more complex aspects of the Supreme Court of the U.S.

The undersigned organizations (“the Business Community”) offer these comments in response to Office of Management and Budget’s (“OMB”) April 7, 2023, “Request for Comments on Guidance Implementing Section 2(e) of the Executive Order of April 6, 2023.” The Business Community recommends to OMB that it withdraw the draft guidance and recommends to President Biden that he restore the original Executive Order 12866. The Office of Information and Regulatory Affairs’ (OIRA) open-door policy granting meetings to any party interested in a regulation under review has reinforced the rigor and legitima

The Partnership to Protect Workplace Opportunity (PPWO or Partnership) and the 104 undersigned organizations again urge the Department of Labor’s (DOL or Department) Wage and Hour Division to abandon or at least postpone issuance of its announced proposed rulemaking altering the overtime regulations under the Fair Labor Standards Act (FLSA). The Department's Fall 2022 Regulatory Agenda targeted this May for release of a proposed rule.

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.

On behalf of the members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to again thank the Surface Transportation Board (STB) for meeting with us on January 24th and to update the STB on issues that we have confronted with freight rail service in early 2023. As a reminder, the  NSSGA membership comprises of stone, sand, and gravel manufacturers and the equipment makers and service providers who facilitate their operations. Our member firms contribute to over 90% of the crushed stone and 70% of the sand and gravel used yearly in the United States.