FR 2025-03485

The document under discussion is a notice from the Department of Labor (DOL) announcing a proposed information collection request. This request has been submitted to the Office of Management and Budget (OMB) for review. The document is primarily focused on certain agricultural forms and applications related to temporary employment certification, specifically the Criteria and Non-Criteria Agricultural Clearance Order Forms and the H-2A Application. The DOL intends to bring back earlier versions of these forms, which were used before a specific regulation dubbed the Farmworker Protection Final Rule went into effect. The public has been invited to submit comments on this proposal by April 3, 2025, in accordance with the process set by the Paperwork Reduction Act.

Significant Issues or Concerns

One notable issue with the document is the lack of detail regarding the specific changes or reasons for reverting to previous forms. While the document mentions reinstating the forms used prior to the Farmworker Protection Final Rule, it does not clearly explain the rationale behind this decision. This leaves the reader guessing about the potential implications and motivations for reverting to old forms.

Moreover, the use of technical terms such as ETA-9142A and ETA-790 can make the document hard to understand for those not familiar with these specific forms. Additionally, the document contains legal references, such as "44 U.S.C. 3507(a)(1)(D)" and terms like “PRA authorization” and “ICR,” which might not be readily comprehensible to someone without a legal or bureaucratic background.

Impact on the Public

Broadly speaking, this document may not significantly impact the general public outside of those directly involved in agricultural employment or labor law. However, for those who are affected, such as farmworkers or employers in the agricultural sector, the form's reinstatement could mean a change in the process of hiring temporary workers. It is essential that the public, particularly those in agriculture, understand and have the opportunity to comment on these changes.

Impact on Specific Stakeholders

For agricultural employers, reverting to earlier forms may either streamline the process if the older forms are more familiar or easier to use or create confusion if stakeholders prefer the newer forms. Similarly, agricultural workers and farmworker advocates might have concerns about how these changes could affect employment conditions or protections supposedly enhanced by the Farmworker Protection Final Rule.

The DOL's call for comments also invites stakeholders to provide input, which could positively impact policy formulation by incorporating a broad range of perspectives. However, the lack of specificity in the feedback instructions may limit the quality and relevance of responses, potentially impeding constructive engagement.

In summary, while the document aims to inform about a proposed collection of information, its technical nature and lack of clarity may obscure its significance for the average reader. This could potentially hinder public engagement and feedback on important regulatory procedures in the agricultural sector.

The document titled "Agency Information Collection Activities; Submission for OMB Review; Comment Request; Criteria and Non-Criteria Agricultural Clearance Order Forms and H-2A Application for Temporary Employment Certification in States and by Employers Covered by Injunction of the Farmworker Protection Final Rule" from the Department of Labor's Employment and Training Administration contains a section related to financial references.

In the section titled "Total Estimated Annual Other Costs Burden," it is noted that the total estimated annual other costs burden is $0. This indicates that, within the scope of the information collection request discussed, there are no anticipated additional costs to the public beyond the time burden estimated elsewhere in the document. Such a statement can be significant as it implies that financial allocations or budget appropriations from the agency are not negatively impacted by this request, and no additional funding is required from respondents to comply.

Financial References in Context

The absence of an additional cost burden is important in understanding the overall impact of the information collection request on individuals, businesses, and government entities. However, this singular financial reference does not provide comprehensive insights into other financial aspects of the information collection, such as potential long-term economic benefits or costs related to the use of the collected data.

Considering the identified issues in the document, it would be beneficial if further context were provided regarding the economic implications of reinstating the previous versions of forms. Specifically, why the forms are being reinstated without changes in relation to the Farmworker Protection Final Rule and how this decision might financially affect the stakeholders involved could be elucidated.

Additionally, while the document provides the total estimated number of respondents and responses, there is no accompanying financial analysis that explains how these figures might translate into potential cost savings or expenditures for stakeholders. The document could enhance its transparency and usefulness by detailing how these estimates were calculated and what assumptions underlie these numbers, especially from a financial perspective.

Furthermore, the absence of financial implications related to public comments reflects a lack of engagement with potential monetary concerns from stakeholders. Addressing how feedback might financially influence or refine the proposed information collection could enhance the comprehensiveness of the document's financial discourse.

In sum, while the document states an estimated financial burden of $0, which suggests no immediate additional costs, further explanation and financial analysis could provide greater insights into the broader fiscal implications of the information collection request.