AILA, ImmigrationWorks USA, Colorado Ski Country USA and many other organizations and individuals offer comments on DOL's proposed changes to the H-2B regulations. Excerpts below.
"[W]e conclude that the proposed rule would have significant adverse consequences for a broad swath of American businesses that rely on the H-2B program. Restaurants, hotels, nurseries, landscapers, lawn care companies, forestry businesses, seafood processors, fisheries, golf courses, ski resorts, amusement parks and a variety of construction firms, among others, would find their businesses hamstrung by the new regulations, and their cost of doing business would increase, in many cases dramatically. If the proposed rule is implemented, many companies will stop using the H-2B program. A significant number might go out of business. The consequences for U.S. workers will be exactly the opposite of what the Department of Labor intends: rather than opening jobs for Americans and improving their working conditions, the new rule will force many H-2B employers to downsize or close, shedding U.S. jobs and generating less economic activity up- and downstream in the local economy." - ImmigrationWorks USA
"We are greatly concerned that implementation of the proposed rule will significantly increase the complexity and costs associated with an already complicated regulatory scheme. The proposed changes will make it exceedingly difficult for employers to continue to temporarily supplement their workforces with H-2B workers." - AILA
"The proposed rule would increase the costs and complexity of the H2B program by orders of magnitude and, in doing so, will make the program virtually impossible for law-abiding seasonal employers to use." - CSCUSA
[Full disclosure: I am a native of Colorado, so the ski industry is near and dear to my heart, and our law firm represents many employers that use the H-2B program. All comments, pro and con, can be viewed and downloaded at regulations.gov.]