Comment from Nowlan, Michael

Summary: Michael P. Nowlan, an attorney, opposes the proposed rule because it fails to provide a specific dollar amount for how the H-1B program has reduced U.S. worker pay, making the proposed wage increases arbitrary and capricious. He argues that the rule will make hiring H-1B workers prohibitively expensive, leading to a decrease in international students at U.S. universities and an increase in offshoring.