The BlueGreen Alliance (BGA) unites the nation’s labor unions and environmental organizations to solve today’s environmental challenges in ways that create and maintain quality jobs and build a stronger, fairer economy. Our partnership is firm in its belief that we don’t have to choose between a good job and a clean environment—we can and must have both. BGA welcomes this extended opportunity to comment on the Draft Programmatic Environmental Assessment (PEA) for Modernization and Internal Expansion of Existing Semiconductor Fabrication Facilities under the CHIPS Incentives Program. The document’s authors are to be commended for their comprehensive overview of the semiconductor industry and analysis of the direct, indirect, and cumulative effects of possible CHIPS-supported projects.

Below we lay out opportunities to more fully realize the administration’s objectives in nurturing good jobs, healthy communities, and a fairer economy. BGA strongly urges the incorporation of these crucial elements in any future PEAs. In addition, as a result of the prevalence of wage theft on construction projects of this magnitude, it is imperative that DOC has a plan to work with the Department of Labor and Office of Federal Procurement Policy, Contract Labor Advisor Group (CLAG) to establish an office with designated staff to deliver a robust plan to enforce Davis-Bacon Act and Related Acts (DBRA) and other labor provisions in CHIPS.

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