The undersigned associations, businesses and stakeholders submit these comments to the Department of Labor (“DOL”) in response to its Notice of Proposed Rulemaking and Request for Comments Regarding Employee or Independent Contractor Classification Under the Fair Labor Standards Act (“FLSA”) (the “Proposed Rule”).1  The current DOL rule regarding independent contractor classification, which went into effect on March 8, 2021 (the “2021 IC Rule”)2 provides badly needed clarity, uniformity, and simplicity to the independent contractor analysis and accounts for the realities of the modern

On behalf of the 400 members of the National Stone, Sand & Gravel Association (NSSGA) I am writing to take the opportunity to comment on the Department of Labor’s (the Department), Wage and Hour Division’s proposed rule “Employee or Independent Contractor Classification Under the Fair Labor Standards Act.”  NSSGA represents aggregates producers and those who manufacture equipment and services that support the construction industry.

The National Stone, Sand & Gravel Association (“NSSGA”) submits these written comments to the Surface Transportation Board (“STB” or “Board”) pursuant to the November 22, 2022, Notice from the STB in the proceeding referenced above, which permits interested stakeholders to submit testimony or comments on the issues raised in the November 22, 2022, Notice in this matter. NSSGA is the leading voice and advocate for the aggregates industry. Our members are stone, sand, and gravel producers and the equipment manufacturers and service providers who support them.

On behalf of the over 400 members of the National Stone, Sand & Gravel Association (NSSGA), I am writing to express our support for the Water Resources and Development Act of 2022. NSSGA would like to applaud Congress in their efforts to include the crucial WRDA language in this year’s National Defense Authorization Act (NDAA); as this piece of legislation will support efforts to improve and invest in all levels of our nation’s infrastructure network, including critical navigable waterways that are essential to America’s economic competitiveness.

The 33 national associations and construction trade unions of the Transportation Construction Coalition (TCC) applaud your work on the Water Resources Development Act of 2022 (WRDA 2022). This bipartisan legislation will authorize much needed investment for U.S. Army Corps of Engineers (Corps) projects, including ports, dredging, locks, levees, dams, and water supply projects and we support its passage and enactment.

Federal investment in infrastructure is critical to sustaining economic growth and quality of life improvements as the nation moves beyond the COVID-19 pandemic. After years of promises of a large infrastructure bill, Congress and President Joe Biden delivered with the enactment of the Infrastructure Investment and Jobs Act (IIJA) nearly 13 months ago. The investments from the IIJA are beginning to have real world impacts as numerous agencies begin to roll out programs and resources at a time when investing in our supply chain could not be more important.

The Coalition for a Democratic Workplace (“Coalition”) responds to the National Labor Relations Board’s (“Board”) Notice of Proposed Rulemaking (“NPRM”) on “Standard for Determining Joint-Employer Status.”  This proposed rule has problems – a lot of problems.  Respectfully, the Board should start over or leave the current standard in place. The proposed rule purports to be grounded in common law agency principles but instead presents an illdefined standard for joint employer liability that sinks to the level of an arbitrary and capricious agency action.

On behalf of the undersigned organizations, we write in strong support of the Family and Small Business Taxpayer Protection Act, H.R. 9092. This legislation would rescind the Inflation Reduction Act of 2022’s billions in funding for the Internal Revenue Service’s (IRS) expanded enforcement efforts, while retaining funding for the IRS to focus on improving taxpayer services and modernizing operations to serve taxpayers.

As the President & CEO of the National Stone, Sand & Gravel Association (NSSGA), I am writing to implore Congress to avert a rail strike at all costs. The association’s 400 members are a critical part of effectively implementing the bipartisan infrastructure bill. They rely heavily on freight rail to get products where they need to be. A freight rail strike would have a tremendous impact on our industry’s ability to supply the construction materials needed for projects around the country.

We the below signed members of the Americans for Transportation Mobility write in support of the two Waivers to the Buy America Requirements for Construction Materials. The new requirements created by the Build America, Buy America Act (BABA) included in the Infrastructure Investment and Jobs Act (IIJA) introduce significant changes to existing Buy America requirements that require additional analysis and guidance from the Administration to implement.