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. 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. Our industry exists side-by-side with nature, and many of our members voluntarily set aside areas of their property for wildlife habitats. However, we are concerned about the level of discretion granted on a case-by-case basis and the lack of clear guidelines on how this discretion will be applied. Businesses need to understand what is and is not regulated in order to comply and require clarity to operate and for informed resource allocation. NSSGA believes that the protection of endangered species is important, and supports a consistent, transparent and scientific approach to protection, while balancing the need for continued economic growth.