Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
Click ‘Read More,’ to open the PDF, with the option for download.

ACA Submits Comments to USGBC on LEED v5

This letter consolidates ACA’s comments to U.S. Green Building Council (USGBC) on LEED v5, which is the newest version of LEED. LEED (Leadership in Energy and Environmental Design) is the world's most widely used green building rating system and is globally recognized as such.

Read More…

ACA, Coalition Urge CRA Resolution on EPA's PM2.5

ACA signed onto a coalition letter urging Congressional leaders to pass a Congressional Review Act resolution to disapprove the U.S. EPA’s recently finalized rule that unnecessarily tightened the National Ambient Air Quality Standards for fine particulate matter (PM2.5), which will have an adverse impact on economic growth.

Read More…

ACA Joins Letter to IRS on Superfund Chemical Taxes

ACA joined several other organizations representing American businesses subject to the excise taxes, reinstated by the Infrastructure Investment and Jobs Act, on certain chemicals and imported chemical substances under Internal Revenue Code sections 4661 through 4672 beginning July 1, 2022 (the “Superfund taxes”). ACA and others asked IRS for additional clarity on the process by which eligible companies may receive a refund on paid Superfund taxes.

Read More…

ACA Joins Multi-Organization Letter to EPA on CARB Locomotive Request

In the letter, the organizations raise serious concerns about an authorization request from the California Air Resources Board (CARB) pertaining to rail locomotive emissions. This regulation from CARB has the potential to create significant disruptions in the supply chain for all sectors of the U.S. economy, especially manufacturers and shippers who rely on consistent, reliable rail service.

Read More…

ACA, Coalition Comments to Congress on Recent RMP Amendments

ACA was among 14 organizations that submitted joint comments to the Congress seeking support for legislation, H.J.Res.123, that disapproves of the recent finalized amendments to the Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (“RMP rule”).

Read More…

ACA Comments on EPA’s Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials

ACA submitted comments to the U.S. Environmental Protection Agency (EPA) on its Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials. EPA is developing a program to identify and label construction materials and products that have substantially lower embodied carbon as part of the Inflation Reduction Act. This is in coordination with General Services Administration and Department of Transportation Federal Highway Administration.

Read More…