Comment from AILA and American Immigration Council
AILA and American Immigration CouncilOpposeAdvocacy
Summary: The American Immigration Lawyers Association (AILA) and the American Immigration Council (Council) oppose the proposed rule, arguing that it lacks sufficient evidence of systematic wage suppression and fails to consider less burdensome alternatives. They contend that the sweeping changes to prevailing wage methodologies will disrupt long-standing reliance interests for employers and foreign workers while causing significant financial harm to industries like higher education.
The American Immigration Lawyers Association (AILA) and the American Immigration Council (the Council) submit a joint comment. Our collective expertise and experience make us particularly well-qualified to offer views that will benefit the public and the government. AILA and the Council oppose this Proposed Rule as it does not offer an accurate assessment of the current prevailing wage methodology and fails to consider less burdensome alternatives to achieve its objectives. Instead, it relies on insufficiently supported logic to justify sweeping changes that will harm, if finalized as proposed, United States employers, as well as foreign and United States workers, as explained in more detail below. We urge the Department of Labor to withdraw this rule in its entirety.