The Waters Advocacy Coalition (WAC) applauds your leadership in holding today’s hearing on “America Builds: Clean Water Act Permitting and Project Delivery.” WAC represents a large and diverse cross-section of the nation’s broad business community, including the construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors.

The undersigned diverse group of construction and business associations—whose membership employs millions of construction industry professionals who successfully build and rebuild America— write to ask you to eliminate President Biden’s Executive Order 14063 and related final rule requiring federal construction contracts of $35 million or more to be subjected to divisive project labor agreements.

We respectfully request that the Environmental Protection Agency (EPA) withdraw the December 13, 2024 proposed Multi-Sector General Permit (MSGP) for stormwater discharges associated with industrial activity.1 We are extremely disappointed in this proposal for several reasons, most importantly that it imposes substantial additional costs on small businesses without any evident additional benefits.2 The next Administration should have the opportunity to thoroughly re-examine this proposal, using the Executive Order 12866 review process.

The undersigned organizations, representing millions of Main Street businesses operating in every industry and community in America, applaud the Department for its swift action in pausing the Corporate Transparency Act’s (CTA) reporting requirements while a nationwide court order remains in place, and respectfully ask that you strengthen this action by administratively extending the CTA filing deadline until at least January 1, 2026.

The undersigned organizations appreciate the opportunity to provide input on the U.S. Fish and Wildlife Service’s (Service) proposed expansion of the Okefenokee National Wildlife Refuge (Refuge) Boundary. Our organizations represent a large and diverse cross-section of America’s agriculture, construction, energy, forestry, manufacturing, and mining sectors. Our members are vital to building a thriving national economy and are essential to achieving the nation’s critical infrastructure, supply chain, transportation, and energy goals.

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. 

The National Stone, Sand & Gravel Association (NSSGA) offers the following comments on EPA’s proposed disapproval of the Texas State Implementation Plan (SIP) provisions for maintenance, startup and shutdown (MSS) provisions for visible emissions and particulate matter.1 NSSGA urges EPA to abandon its proposal as inconsistent with the fundamental principles underlying the Clean Air Act (CAA) and relevant judicial decisions, and to approve the Texas SIP provisions at issue.

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.

I write on behalf of the over 450 members of the National Stone, Sand & Gravel Association (NSSGA) to express our support for your amendment, Palmer #80, to H.R. 8998, the Department of the Interior, Environment and Related Agencies Appropriations Act, 2025. This amendment, which prohibits funds from being used to implement, administer or enforce the final rule, "National Emission Standards for Hazardous Air Pollutants (NESHAP): Lime Manufacturing Plants Technology Review," would benefit our industry and we urge the House of Representatives to pass it.

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.