Positive Management Leadership, Inc., Dunn, Terrence Jr

I am very concerned about the DOL posting to the Federal Register a proposed revision to the Labor-Management Reporting and Disclosure Act and its Interpretation of the ‘‘Advice’’ Exemption. DOL’s new proposed reporting rules are so broad and vague as to capture every single moment, activity or word used by an employer to educate employees about their federally protected rights under the National Labor Relations Act (NLRA) to NOT form or join unions. Unions assuredly are not be interested in educating company employees about these federally protected rights; for their existence, they depend on attracting dues-paying members. The DOL’s new rules will force employers to pay a new tax for their efforts to create a positive workplace and educate their employees about their rights under the NLRA. The DOL’s new rules equate to state censorship on companies and individuals, and represent a clear attack on the First Amendment rights to Freedom of Speech. DOL proposes a hefty “price” to any company which exercises freedom of speech and its message is clear: a company and its managers can exercise free speech as long as the company and its managers spend precious resources in tracking, reporting and defending free speech. The imposition of needless, taxpayer-funded bureaucracy and the related unnecessary costs to American businesses have absolutely nothing to do with helping employers to compete or to create jobs. I believe this is a criminal misuse of taxpayer resources and of the other important work at the DOL. I believe that the U.S. Congress should - - for the good of the economy, U.S. competitiveness and job creation, and of our constitutionally guaranteed rights - - intervene with the DOL up to and including defunding the agency from imposition of this activity. I believe that the DOL should cease its attempt to force companies from reporting on their exercise of free speech rights. Respectfully, Terrence C Dunn Jr