TNT Lawn & Landscape Mgmt., Inc. - Twist, Charles

In response to: "The Department has similarly concluded that this proposed rule is not a major rule requiring review by the Congress under the SBREFA because it will not likely result in: (1) An annual effect on the economy of $100 million or more; (2) a major increase in costs or prices for consumers, individual industries, Federal, State or local government agencies, or geographic regions; or (3) significant adverse effects on competition, employment, investment, productivity, innovation, or on the ability of U.S.-based enterprises to compete with foreign-based enterprises in domestic or export markets." All of these statements are to the contrary. 1. You never once contacted, interviewed or investigated the impact this ruling will have to my company or any other company that utilizes the H-2B program. You really DO NOT KNOW for sure if this ruling will result in an annual effect on the economy of $100 million or more. The impact of businesses closing their doors and downsizing must also be taken into consideration as well as hidden costs that were never taken into account. 2. In most instances, there of course would NOT be any major increase in costs or prices for consumers, because the employer cannot substantially raise his prices to reflect these salary increases and still remain competitive. The employer will be forced to accept being less profitable, go out of business, or downsize. The wages being FORCED upon H-2B users are NOT competitive wages. 3. This ruling, to the contrary, WILL have a significant adverse effects on competition, employment and investment. These wages that are being forced upon H-2B user companies are NOT competitive wages. The playing field is UN-LEVELED significantly by this ruling. How can we be competitive if the competition is not required to pay the same wages? Companies will cut back on the number of employees they hire due to this ruling. Companies will cut back on all spending. The new start date exasperates it