Position paper from the Essential Raw Materials Coalition — representing aggregate producers, industrial mineral extractors, and construction material manufacturers — submitted in response to the CRMA proposal, arguing that the Act’s permitting fast-track provisions and strategic materials designation should extend to aggregates and construction minerals not covered by the existing criticality methodology. The Coalition’s case rests on a straightforward observation: the EU cannot deliver the infrastructure its green transition requires without the aggregates that go into every road, building, and foundation, yet none of these materials qualify as critical under a framework calibrated to high-tech supply chains. The submission is a direct challenge to the assumption that criticality should be defined by substitutability difficulty rather than deployment volume.