Comment submitted by Steel Manufacturers Association (SMA)

Summary: The Steel Manufacturers Association (SMA) supports the proposed definitions of “begin actual construction” and “pollutant-emitting activities,” stating they provide a clearer and more practical framework for regulated entities. The association requests specific additions to the exclusion list, including site access, safety infrastructure, stormwater management, and various construction-related activities, arguing that these do not constitute pollutant-emitting processes and would reduce project delays.