Comment from Murray, Jeff

See the attached file for the entirety of my comments. Public Comment on DOL NPRM: Docket No. ETA-2026-0001 Re: Opposition to Proposed Revisions to Prevailing Wage Methodology for PERM, H-1B, H-1B1, and E-3 Programs – Demand Complete Termination of These Programs Under America First Principles Submitted via regulations.gov on or before May 26, 2026.The Department of Labor’s NPRM (Federal Register Vol. 91, No. 59, March 27, 2026) proposes tweaking the four-tier prevailing wage structure based on OEWS data—raising Level I from the 17th to 34th percentile, Level II from 34th to 52nd, Level III from 50th to 70th, and Level IV from 67th to 88th. The stated goals are to “better align” wages with U.S. workers, reduce incentives for employers to “replace, rather than supplement” American labor, and prevent adverse effects on U.S. wages and conditions.This is a half-measure at best and a deliberate distraction at worst. The NPRM itself repeatedly admits the programs’ systemic failures: hundreds of thousands of H-1B certifications annually (502,374 in FY 2024 alone), massive overlap with PERM (57.6% of PERM apps from current H-1B workers), and explicit recognition that employers exploit these visas to hire lower-paid foreign nationals in specialty occupations. Raising wage floors by a few percentiles does nothing to address the root problem: these programs exist to import foreign labor that displaces and undercuts American workers. The ill-intentioned core of this rulemaking is to perpetuate and legitimize a broken system rather than dismantle it. DOL should withdraw the NPRM entirely and instead initiate rulemaking to terminate the H-1B, H-1B1, E-3, and PERM (EB-2/EB-3) programs.