The organizations signed below collectively submit the following comments on the Federal Highway Administration’s (FHWA) Notice of Proposed Rulemaking (NPRM) filed March 12, 2024 entitled “Buy America Requirements for Manufactured Products”. The Federal Highway Administration’s (FHWA) NPRM to rescind the 1983 Manufactured Product Waiver in order to comply with the requirements of Build America, Buy America Act (BABAA) section 70914 generally tracks the legal requirements of BABAA as well as the Office of Management and Budget (OMB) guidance and 2 Code of Federal Regulations (CFR) 184 amendment. Because Title 231 contained a pre-BABAA Buy America preference requirement for steel, iron and manufactured products, the existing waiver authority for manufacture products utilized by FHWA was subject to review by Section 70917(a) of BABAA to determine its consistency with the requirements of section 70914 of BABAA. This waiver has been in place since 1983, and was codified in 2005.2 Importantly, the existing FHWA Buy America requirements do not include authority regarding construction materials.