DHI llc - Holloway, James

After carefully reading the proposed rule change for Temporary Labor Certification, I noticed a huge inconsistency. The stated reasons for making the change are due mainly to the increase in applications,which according to INS and the DOL have risen 129% since the year 2000. Without the “exemption” for returning workers provided by the Save Our Small and Seasonal business act, it would seem apparent that there would be a significant decrease in applications for temporary workers due to numerical cap of 66,000. Without an increase in the numerical cap or a return of the “exemption” it doesn’t make sense that an increase in applications would continue. While we are not philosophically opposed to the changes and to the proposed increase in application/administration filing fees. We do feel that any legislation submitted by the Department of Labor to Congress in order increase these fee’s must also include significant increases in the numerical cap ( at minimum 132,000 new workers) or reapply the “exemption” as Proposed in the Save our Small and Seasonal businesses Act of 2007. Without changes to the numerical limits, changes to the process will be pointless.