Baked ini Telluride - Greene, Jerry

Document ID: ETA-2013-0003-0194
Document Type: Public Submission
Agency: Employment And Training Administration
Received Date: June 10 2013, at 12:00 AM Eastern Daylight Time
Date Posted: June 12 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: April 24 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: June 10 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-85tz-z4in
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I operate Baked in Telluride, a bakery in the resort town of Telluride, Colorado and have hired bakers under h2b for a decade. When I started I did almost all the work myself, including personally transporting workers from their home countries. The program now requires a mountain of paperwork, and consumes dozens of hours work far in excess of Paperwork Reduction Act estimates. Through all this, the availability of people to fill the job without foreign labor has decreased, recession or no. My seasonal needs can only be met with the h2b candidates. I am aware of local wages and pay fairly. I have always paid travel costs and visa related expenses. My h-2b workers never pay recruiting costs. I recruit solely on my own. It is unreasonable for the DOL to set wages through flawed statistical analysis. Neither DOL nor DHS have the legal authority to set h-2b wages. Congress authorized two means for protecting against adverse wage effects. The market test and the cap. They must be followed. I survey the local labor market. I can attest that congress’ methods are accurate and that I set wages fairly in accordance with my workers and the local labor market. The current dispute over wage determination has contributed nothing to the availability of workers and has not affected local wages. It has only contributed to the endlessly growing bureaucracy which delivers no benefit to local or foreign workers, and only increases the cost to businesses. Documented workers are not available to fill these baker positions, and paying more will only increase prices I charge for my products, which is decidedly not a benefit. is unreasonable for the DOL to set watarbitrary through flawed statistical analysis, Neither DOL nor DHS have the legal authority to set h-2b wages. Congress authorized two means for protecting against adverse wage effects. The market test and the cap. The DOL seems to have no regard for the welfare of small business or their workers or customers.

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