Executive Departments

NSSGA Comments to CEQ on NEPA's Proposed Rule

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comment in response to the Council of Environmental Quality’s (CEQ) National Environmental Policy Act (NEPA) Implementing Regulations Revisions Phase 2 proposed rule (“Proposed Rule”).

Coalition Comments to CEQ on NEPA's Proposed Rule

The undersigned associations (collectively, the “Coalition”) offer the following comments in response to the Council on Environmental Quality’s (“CEQ’s”) proposed National Environmental Policy Act (“NEPA”) Implementing Regulations Revisions Phase 2 (“Proposed Rule”). 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.

Coalition Comments to Department of Labor Requesting an Extension to the Comment Period on Proposed Rule

The Partnership to Protect Workplace Opportunity (PPWO) and the 107 undersigned organizations write to you to request a 60-day extension to the comment period on the agency’s above-referenced notice of proposed rulemaking in order to provide the regulated community with sufficient time to analyze and respond to the Wage and Hour Division’s (WHD) proposed changes to the overtime pay exemptions for executive, administrative, professional, outside sales, and computer employees.

Comments to OMB RE: Request for Comments on Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comments in response to the Office of Management and Budget’s (“OMB”) Aug. 2, 2023, “Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis” (Draft Guidance). Our industry is heavily regulated from federal, state, and local entities. These regulations are ever changing, and many times are contradictory, causing significant delay and expense for approving projects.

NSSGA Comments on MSHA's Proposed Silica Rule

On July 13, 2023, The Mine Safety and Health Administration (MSHA) published a proposed rule, “Lowering Miners' Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” The National Stone, Sand and Gravel Association (NSSGA) and our member companies have carefully reviewed and analyzed the proposed standard. We respectfully submit the following comments, which include issues, recommendations, and most importantly, rationale backed by research and data.

Coalition Comments to CEQ Urging a Comment Period Extension on the Proposed Rule to Amend Procedural Provisions of NEPA

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.

NSSGA Comments on U.S. Fish and Wildlife Services Proposed Listing Endangered and Threatened Species and Designating Critical Habitat; Implementing Proposed Changes to the Regulations for Designating Critical Habitat under the ESA; Docket No. FWS–HQ–ES–20

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 Comments on U.S. Fish and Wildlife Service Proposed Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants, 50 CFR 17

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.

RCC Letter to President Biden on STB Chairman and Member Renominations

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.

Letter to MSHA Requesting an Extension of the Comment Period for the Proposed Silica Rule

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.

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