January 13, 2011
January 13, 2011
The Honorable Mary L. Schapiro
Chairman
Securities and Exchange Commission (SEC)
100 F Street NE
Washington, D.C. 20549
Re: Proposed Rules to Implement Special Disclosures Sections 1502 Conflict Minerals
1503 Mine Safety and 1504 Disclosure of Payments of the Dodd-Frank Act (S7-40-10, S7-41-10 and S7-42-10)
Dear Chairman Shapiro:
On behalf of the National Stone, Sand Gravel Association (NSSGA), we request an extension of the comment period for the proposed rules to implement Sections 1502, 1503 and 1504 of the Dodd-Frank Act. We appreciate the opportunity to comment on these important initiatives however, the current deadline does not provide sufficient time for us to collect pertinent information and provide responses to the extensive questions in the proposed rules. To allow industry to provide the information sought, we request a 30-day extension of the comment period.
Based near the nations capital, NSSGA is the worlds largest mining association by product volume. Its member companies represent more than 92 percent of the crushed stone and 75 percent of the sand and gravel produced annually in the U.S. and approximately 118,000 working men and women in the aggregates industry. During 2008, a total of nearly more than 2.3 billion metric tons of crushed stone, sand and gravel, valued at $21 billion, were produced and sold in the United States.
We would contend that the extension is justified because the stated deadline does not provide sufficient time to provide a meaningful and comprehensive submission given the complexity and scope of comments requested. Additionally, the comment period fell at a time of year in which many companies were closed for the holidays or employees are out of the office on leave. Yet, without adequate response from regulated entities, the final regulations could have inadvertent and adverse consequences.
We appreciate the work done by the Securities and Exchange Commission (SEC) to draft the proposed rules, and want to ensure that stakeholders have adequate time to provide important feedback. We respectfully urge, therefore, that the deadline for comments be extended 30 days to March 2, 2011.
Should you have any questions on this request please contact me at (703) 526-1074, or at jcasper@nssga.org. Thank you very much for your consideration of this request.
Sincerely,
Joseph S. Casper
Vice President, Safety