Comment from Obelisk Tech Systems Inc. May 26, 2026 Forced Labor, China Policy Bank, 60 Economic Harms with HTS, and Trade Risk

I request that the Employment and Training Administration preserve this submission, all attachments, metadata, upload records, and any internal routing records as part of the administrative record for RIN 1205-AC11 (Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States). I further request that this submission be referred to the Office of the Solicitor, the Wage and Hour Division, the Office of Foreign Labor Certification, the Bureau of International Labor Affairs (ILAB), the DOL Office of Inspector General, and any other offices responsible for evaluating whether prevailing wage methodology, attestation integrity, and program integrity accounts for forced-labor exposure, foreign state-subsidized labor distortion, supply-chain coercion, and the resulting injury to domestic workers, HUBZone firms, SDB/8(a) firms, and FEMA disaster-area small businesses.The attached materials are submitted to demonstrate that wage protection rulemaking cannot be evaluated in isolation from the operational labor-coercion environment facing the United States. Prevailing wage determinations rely on labor market data assumptions that are systematically distorted when foreign labor inputs — at the country-of-origin level, at the upstream supplier level, and at the importer-of-record level — are produced under conditions of forced labor, debt bondage, state-directed labor transfer, or sovereign subsidy. When DOL sets a prevailing wage floor without accounting for the coerced-labor baseline distorting comparable occupations and industries, the floor itself becomes a vehicle for importing wage suppression into the domestic labor market.The 60-economy commercial injury record attached here documents, on a country-by-country basis, the self-admitted forced labor exposure across the supply chains feeding U.S. employers who utilize H-1B, H-2A, H-2B, and PERM channels. The Executive Orders attachment establishes the legal authority chain (EO 13126, EO 14257, UFLPA, 19 USC 1307, TVPRA) that DOL is statutorily required to coordinate with under existing interagency duties. The CLG-Global field definitions and TUFF methodology materials establish the data-integrity standard for tracking foreign state financing that subsidizes coerced labor regimes whose wage data then contaminates U.S. prevailing wage calculations.The companion documents on FEMA disaster-area small business, HUBZone structural injury, SDB/8(a) structural injury, and OMB/OIRA Made-in-America data integration establish the downstream injury to U.S. small business sectors when wage protection methodology fails to internalize forced-labor exposure. Each of these populations is statutorily protected under separate federal authorities, and ETA's wage methodology has cross-cutting effects on all of them.I do not submit these materials as a narrow comment on wage methodology alone. I submit them as evidence that the definition, justification, and operational application of prevailing wage protection must be tied to the real labor-coercion environment in which U.S. employers operate. Where ETA lacks methodology able to detect, analyze, and correct for foreign state-backed labor distortion, the consequence is not merely wage erosion. The consequence is the conversion of the federal wage protection apparatus into a transmission mechanism for foreign labor coercion into the domestic economy, with direct injury to U.S. workers, U.S. small businesses, HUBZone firms, SDB/8(a) firms, and disaster-impacted communities.Please preserve this submission and attachments in the docket, review them as part of the rulemaking record, and forward them to all relevant DOL offices and interagency personnel responsible for legal, regulatory, wage-policy, foreign labor certification, international labor affairs, procurement integrity, and inspector general review.Respectfully submitted,James H. Poole Executive Chairman & CEO Obelisk Tech Systems Inc. CAGE: 9S0L8 | UEI: U34MSJ6A6413 ITAR DS-2032 Registrant | HUBZone-Certified Thomasville, Georgia