We are pleased to submit comments on the Environmental Protection Agency’s proposal titled “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process” (40 CFR 83). We strongly support EPA’s continuing efforts on regulatory reform. Numerous regulations, rules or other requirements include costs that drastically outweigh small or nonexistent gains in environmental quality. Good government relies on reasonable regulations that are supported by sound science and provide certainty and clarity for industry. An important part of rulemaking is public notice and comment, and this process can only be improved if stakeholders have access to good quality data and information, including benefits and costs.
As the National Stone, Sand & Gravel Association (NSSGA) is the leading advocate for the aggregates industry, we make the following recommendations that are certain to assist our industry, have a positive impact on the economy and create jobs. The aggregates industry employs more than 100,000 highly skilled men and women. Our industry generates $27 billion in annual sales and supports $122 billion in national sales in affiliated industries. Every job in the aggregates industry supports an additional 4.87 jobs throughout the economy. Our members – stone, sand and gravel producers and the equipment manufacturers and service providers who support them – are responsible for the essential raw materials found in every home, commercial building, road, runway and public works project from schools to hospitals. This industry works diligently to protect the health of our workers, the public and the environment, but burdensome regulations and red tape that do not improve worker health or environmental quality can only hinder business and adversely affect the communities in which those businesses operate.