2022 03 22 Multi sector LTR on Buy America comment period FINAL


March 22, 2022


The Honorable Shalanda Young


Office of Management and Budget

725 17th Street NW

Washington, DC 20503

Dear Director Young:

The undersigned associations stand ready to work with you and others across the Administration to ensure projects funded through the landmark bipartisan Infrastructure Investment and Jobs Act (IIJA) achieve their full potential.

We understand the Office of Management and Budget (OMB) is working to develop guidance to support federal agencies’ application of the IIJA’s expansion of Buy America requirements. Given the breadth of newly affected infrastructure projects, the sheer amount of funding, the novelty of these requirements in certain sectors, and the ambitious implementation timelines, it is critical that guidance related to the IIJA’s expansion of Buy America requirements fully considers industry’s experience with supply chains and provides for the consistent application of the rules across the federal government. Without sufficient stakeholder engagement to ensure the implementation of Buy America requirements aligns with the realities of the existing commercial marketplace, it is plausible that the planned investments in utilities (e.g., water and power), electric vehicle infrastructure, broadband, roads, and bridges will not come to fruition.

To these ends, we strongly encourage OMB to hold a public comment period to solicit and incorporate necessary stakeholder input prior to finalizing guidance for federal agencies. The stakes are simply too high to undermine the effective realization of IIJA-funded projects owing simply to a lack of stakeholder engagement around new requirements, including a timely and workable waiver process. Seeking public comment in parallel with agency work to develop the IIJA programs should keep potential delays to a minimum.

Thank you for your consideration and your leadership. Our associations are committed to making these projects a success. Providing for formal stakeholder engagement through a public comment period to inform OMB’s guidance would be an important first step to support more seamless implementation in the years to come.


ACT | The App Association

American Clean Power Association

American Council of Engineering Companies

American Public Transportation Association

American Road and Transportation Builders Association

American Society of Civil Engineers

Associated General Contractors of America

Association of Equipment Manufacturers

Information Technology Industry Council (ITI)

National Association of Clean Water Agencies

National Defense Industrial Association

National Electrical Manufacturers Association

National Foreign Trade Council

Portland Cement Association


U.S. Chamber of Commerce

Water and Wastewater Equipment Manufacturers Association

WateReuse Association


The Honorable Thomas J. Vilsack, Secretary, U.S. Department of Agriculture

The Honorable Gina M. Raimondo, Secretary, U.S. Department of Commerce

The Honorable Jennifer M. Granholm, Secretary, U.S. Department of Energy

The Honorable Alejandro Mayorkas, Secretary, U.S. Department of Homeland Security

The Honorable Deb Haaland, Secretary, U.S. Department of the Interior

The Honorable Pete Buttigieg, Secretary, U.S. Department of Transportation

The Honorable Jen Easterly, Director, Cybersecurity and Infrastructure Security Agency

The Honorable Michael S. Regan, Administrator, U.S. Environmental Protection Agency

The Honorable Alan Davidson, Assistant Secretary for Communications and Information,

National Telecommunications and Information Administration

The Honorable Chris McLean, Acting Administrator, Rural Utilities Service

Ms. Celeste Drake, Director, Made in America Office

Mr. Mitch Landrieu, Senior Advisor and Infrastructure Coordinator, White House

2022 03 22 Multi sector LTR on Buy America comment period FINAL