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.

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.

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.

I am writing to express our steadfast support for your initiative to introduce a bipartisan, bicameral Congressional Review Act (CRA) resolution to overturn the NEPA Phase II Final Rule. Your leadership in seeking to correct this regulatory misstep is crucial for ensuring that infrastructure development can proceed efficiently and equitably.

The undersigned associations represent thousands of members that generate trillions of dollars in economic activity and employ millions of workers across this country. We urge you to pass a Congressional Review Act resolution to disapprove the U.S. Environmental Protection Agency’s recently finalized rule that unnecessarily tightened the National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5), which will have an adverse impact on economic growth. Protecting our environment and improving public health are priorities for our members.