The undersigned trade associations welcome the opportunity to comment on the Office of Management and Budget’s (OMB) draft memorandum and toolkit regarding “Broadening Public Participation and Community Engagement with the Federal Government.” We appreciate OMB’s efforts to improve engagement in the rulemaking process. Our associations strongly support fostering robust and inclusive public involvement, as it enhances transparency, builds trust, and leads to better-informed policies. We therefore offer the following comments on specific elements of the draft documents. 

On behalf of the aggregates, cement and concrete industries, we are writing with concerns about S. 2991, America’s Revegetation and Carbon Sequestration Act of 2023. The aggregates, cement and concrete industries supply crucial building materials to every construction project in America, including residential, commercial and public works projects. Our industries have a substantial presence in every state and congressional district in the United States, including 9,500 aggregates facilities, 7,500 ready mixed concrete plants and 95 cement plants cement terminals.

The undersigned organizations write on behalf of millions of American businesses and their employees in all sectors of the U.S. economy. Considering the Supreme Court’s recent decision in Loper Bright Enterprises et al. v. Raimondo we ask your Administration to pause all current rulemakings and stop new rules from taking effect until there is a thorough legal review of each agency’s constitutional and statutory authority to regulate in the way it proposes.

Ahead of the Railroads, Pipelines, and Hazardous Materials Subcommittee’s July 9th Hearing entitled “An Examination of the California Air Resources Board’s (CARB) In Use Locomotive Regulation” we write on behalf of the members of the National Stone, Sand & Gravel Association (NSSGA) and California Construction and Industrial Materials Association (CalCIMA), to express our concerns over the California Air Resources Board’s (CARB) request for EPA authorization of its In-Use Locomotive Regulation. The CARB rule would ban most locomotives that are more than 23 years old starting in 2030.

We, the undersigned trade associations, represent a large cross section of the nation’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 national economy and provide important resources and good paying jobs in local communities across the United States. We hope that the administration will continue to work with our sectors as partners in protecting and enhancing the environment.

Thank you for holding today’s hearing, “Cutting Competition in Contracting: The Administration’s Pricey Project Labor Agreement Mandate.” As you know, on Dec. 22, 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.

We encourage you to co-sponsor H.R. 8204, the Regulatory Early Notice and Engagement Act. This bipartisan legislation would reform the federal regulatory process to make it more transparent, accountable, and responsive to the public. The end result will be better regulation.

On Dec. 22, 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 undersigned trade associations appreciate the opportunity to comment on the Office of Management and Budget’s (OMB) request for information regarding methods and practices for advancing public participation and community engagement (PPCE). We believe it is essential that all individuals have a fair and equal opportunity to petition their government and have their views and interests represented within the federal policy and rulemaking process. Our associations strongly support the free exchange of information and ideas among all stakeholders.

The Coalition for Workplace Safety (CWS) and the 58 undersigned organizations urge your support for Representative Mary Miller’s Congressional Review Act (CRA) resolution to nullify the Occupational Safety and Health Administration’s (OSHA) Final Rule, “Worker Walkaround Representative Designation Process,” published in the Federal Register on April 1, 2024, which would allow third parties looking to harm employers to accompany OSHA safety and health officers during facility inspections.