Thank you for your commitment to conducting oversight of the Infrastructure Investment and Jobs Act (IIJA). To that end, the undersigned organizations support congressional efforts to halt the greenhouse gas performance measure regulation finalized Nov. 23 by the Federal Highway Administration (FHWA). The IIJA represents the most significant infusion of investment in the nation’s infrastructure since the development of the Interstate Highway System in the mid-1950’s.

On behalf of the 450 members of the National Stone, Sand & Gravel Association (NSSGA), we write to express our strong support for the recently introduced bills aimed at enhancing the efficiency and clarity of the Clean Water Act (CWA) permitting processes. NSSGA represents the aggregates and industrial sand industry of our country, with over 9,000 facilities and more than 100,000 employees in high-paying jobs. This industry procures 2.5 billion tons of aggregates annually, which are crucial in sustaining our lifestyle and constructing our nation's infrastructure and communities.

On Dec. 22, 2023, the Biden administration published a final rule, Federal Acquisition Regulation: Use of Project Labor Agreements for Federal Construction Projects, implementing President Joe Biden’s Executive Order 14063, which requires federal construction contracts of $35 million or more to be subjected to anti-competitive and inflationary project labor agreements.

The organizations signed below collectively submit the following comments to the Environmental Protection Agency’s (EPA) Request for Information: Products and Categories of Products Used in Water Infrastructure Programs. We appreciate the opportunity to share our perspective of this review as it relates to our construction materials.

NASHVILLE - WAP Sustainability, the leading U.S. provider of life cycle assessment (LCA) and environmental product declarations (EPDs) services and tools, with support from the National Stone, Sand & Gravel Association (NSSGA), is pleased to announce the launch of Theta EPD for Aggregates. 

- Theta Aggregates is the first “EPD on Demand” tool tailored specifically for North American aggregate producers.

The Waters Advocacy Coalition (“WAC” or “Coalition”) offers the following comments on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams (“Draft Manual”). WAC represents a large cross-section of America’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving economy and provide much-needed jobs.

The National Stone, Sand & Gravel Association (NSSGA) appreciates the opportunity to comment on the U.S. Army Corps of Engineers (Corps) Draft National Ordinary High-Water Mark (OHWM) Manual (manual). NSSGA applauds this extensive compilation of science but is concerned about the lack of clarity about when it should and should not be used. We are especially concerned that it could expand the jurisdictional reach, in conflict with the Supreme Court’s unanimous Sackett ruling and could limit the use of Nationwide Permits (NWPs).

On behalf of the National Stone, Sand & Gravel Association (NSSGA), the National Ready Mixed Concrete Association (NRMCA) and the Portland Cement Association (PCA), we write to you today regarding our deep concern over the proposed Environmental Protection Agency (EPA) particulate matter (PM) standard that is expected to lower the National Ambient Air Quality Standard (NAAQS) particulate matter standard (PM 2.5) from its current level of 12.0 micrograms per cubic meter of air (µg/m3) to within the range of 8.0 to 11.0 µg/m3.

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).

These comments are submitted on behalf of the Coalition for Workplace Safety (“CWS”) and the 74 undersigned organizations (“the Commenters”), pursuant to the Occupational Safety and Health Administration’s Notice of Proposed Rulemaking regarding the Worker Walkaround Representative Designation Process under the OSH Act, 88 Fed. Reg. 59825 (Aug. 30, 2023) (“Proposed Rule”). For the reasons outlined below, the Commenters urge OSHA to withdraw the proposed rule entirely.