Comment from Grant, Rachael

Rachael GrantOpposeIndividual
Summary: The commenter opposes the proposed rule, arguing that the Department of Labor's methodology for setting wage levels is arbitrary, capricious, and lacks a sound empirical basis. They specifically criticize the "specialty occupation discount" theory, the circular "Benchmark Value" analysis, and the failure to adequately consider reliance interests or more accurate alternatives like experience benchmarking.
Please see my comments, attached.

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