Comment from Brunoni, Joseph

OnShoringAmerica Initiative strongly supports the Department’s proposed revisions to the prevailing wage methodology under Docket No. ETA-2026-0001. I appreciate the Department’s recognition that current wage levels have been set too low relative to comparable U.S. citizen workers and that existing methodologies have created incentives to favor foreign noncitizen labor over domestic workers. These changes represent a meaningful and necessary step toward protecting U.S. citizen workers. However, the proposed rule addresses only the wage dimension of a larger structural problem. It does not provide visibility into the full scale of labor substitution, including onshore and offshore foreign labor utilization, international student pipelines into the workforce, or AI-driven automation. Without integrated data transparency and dedicated classification mechanisms, wage adjustments alone treat symptoms rather than the underlying cause.We therefore recommend that the Department consider a complementary structural reform: enhancing the NAICS classification system with three targeted codes to track foreign labor, student-to-workforce transitions, and AI/automation substitution. This data-first approach would enable more precise, responsive policymaking and ensure the prevailing wage reforms achieve their full intended impact. The full 10-page comment, including detailed analysis, Figure 1 on 2026 labor substitution equivalents, and the specific NAICS proposal, is attached to this submission. I appreciate the Department’s leadership on wage protections and welcome further dialogue on advancing comprehensive labor market transparency. Respectfully submitted, OnShoringAmerica Initiative Please DM "J_VITO_B" for any responses See attached file(s)