The organizations signed below collectively submit the following comments to the Federal Highway Administration’s (FHWA) “Review of its General Applicability Wavier of Buy America Requirements for Manufactured Products.” We appreciate the opportunity to share our perspective of this review as it relates to our construction materials.

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.

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 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. 

The organizations signed below collectively submit the following comments on the Office of Management and Budget’s (OMB) proposed amendment to 2 CFR 184 and 200, and responses to questions outlined in the preamble of the notice of the proposed rule. We divide our comments into three sections: 1) Authorities contained in the Build America, Buy America Act (BABAA) provisions of the Infrastructure Investment and Jobs Act (IIJA) pertinent to our construction materials; 2) Responses to questions in the preamble; and 3) Additions and strikes required by BABAA to the proposed rule.

On January 25th, 2023, the General Service Administration (GSA) released for comment the GSA developed minimum requirement standards for Inflation Reduction Act (IRA) funded purchases of materials and products with substantially lower embodied carbon based on, and in accordance with, EPA’s Determination under Section 60503 of IRA. The National Sand, Stone and Gravel Association (NSSGA) appreciate the opportunity to comment on the GSA developed standards to promote the procurement of materials and products available today with the comparatively lower embodied carbon.

ALEXANDRIA, VA – The National Stone, Sand & Gravel Association (NSSGA) President and CEO Michael Johnson issued the following statement on the industry’s bipartisan Buy America exclusion that was issued as part of the Infrastructure Investment and Jobs Act legislation.

ALEXANDRIA, VA –The National Stone, Sand & Gravel Association joined a coalition representing aggregates producers, farmers, home builders and others representing a broad swath of the U.S. economy to file a complaint in the U.S. District Court, Southern District of Texas, Galveston Division on Jan. 18.  NSSGA’s President and CEO Michael Johnson issued the following statement:

Congratulations on your confirmation as Administrator of the Federal Highway Administration (FHWA). As you transition into this new role leading the agency, we respectfully request that you rescind the “Policy on Using Bipartisan Infrastructure Law Resources to Build a Better America” memorandum issued on December 16, 2021. We supported the Infrastructure Investment and Jobs Act (IIJA), because it represents the most significant infusion of investment in our infrastructure since the enactment of the Interstate Highway System in the mid-1950’s.

ALEXANDRIA, VA –The National Stone, Sand & Gravel Association’s President and CEO Michael Johnson issued the following statement after the U.S. Environmental Protection Agency (EPA) and the Army Corps of Engineers (Corps) released their final Waters of the United States (WOTUS) rule. In April, NSSGA joined the American Road & Transportation Builders Association for an amicus brief in the Sackett v.