Executive Departments

Letter to U.S. Army Corps of Engineers and EPA on a Post-Sackett Pause on Approved Jurisdictional Determinations

The National Stone, Sand & Gravel Association (NSSGA) strongly urges the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) (the agencies) to immediately issue a public, post-Sackett memo on approved jurisdictional determinations (AJDs) for areas that are clearly excluded from jurisdiction under the Sackett v EPA (Sackett) opinion. While we agree that an updated rule is needed for more complex aspects of the Supreme Court of the U.S.

Coalition Comments to OMB RE: Request for Comments on Guidance Implementing Section 2(e) of the Executive Order of April 6, 2023

The undersigned organizations (“the Business Community”) offer these comments in response to Office of Management and Budget’s (“OMB”) April 7, 2023, “Request for Comments on Guidance Implementing Section 2(e) of the Executive Order of April 6, 2023.” The Business Community recommends to OMB that it withdraw the draft guidance and recommends to President Biden that he restore the original Executive Order 12866. The Office of Information and Regulatory Affairs’ (OIRA) open-door policy granting meetings to any party interested in a regulation under review has reinforced the rigor and leg

Coalition Letter to Department of Labor on Anticipated Overtime Regulations Under the Fair Labor Standards Act

The Partnership to Protect Workplace Opportunity (PPWO or Partnership) and the 104 undersigned organizations again urge the Department of Labor’s (DOL or Department) Wage and Hour Division to abandon or at least postpone issuance of its announced proposed rulemaking altering the overtime regulations under the Fair Labor Standards Act (FLSA). The Department's Fall 2022 Regulatory Agenda targeted this May for release of a proposed rule.

Comments to EPA on RFI Regarding IRA Programs to Lower Embodied Greenhouse Gas Emissions with Construction Materials and Product

On behalf of the 400 members of the National Stone, Sand and Gravel Association, we appreciate the opportunity to provide feedback and response to the EPA’s RFI to support new IRA programs to lower embodied greenhouse gas emissions with construction materials and products. NSSGA is the leading voice and advocate for the aggregates industry and the businesses that supply them, with member companies representing more than 90 percent of the crushed stone and 70 percent of the sand and gravel consumed annually in the United States.

Letter to STB on Freight Rail Service

On behalf of the members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to again thank the Surface Transportation Board (STB) for meeting with us on January 24th and to update the STB on issues that we have confronted with freight rail service in early 2023. As a reminder, the  NSSGA membership comprises of stone, sand, and gravel manufacturers and the equipment makers and service providers who facilitate their operations. Our member firms contribute to over 90% of the crushed stone and 70% of the sand and gravel used yearly in the United States.

Coalition Comments to NEPA Director, CEQ on Interim Greenhouse Gas Guidance

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.

Comments on EPA's Reconsideration of the National Ambient Air Quality Standards (NAAQS) for Particulate Matter

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. 

Coalition Comments on EPA's Reconsideration of the National Ambient Air Quality Standards (NAAQS) for Particulate Matter

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).

Coalition Comments to OMB Regarding Buy America Provisions of the IIJA

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.

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