My problem with PERM is one of experience with the LCA faxback system that was instituted in 1998. Prior to the faxback system, to apply for an LCA to file an H-1 it was necessary to send the forms to DOL and have them approved and sent back. Then the faxback system came into existence and it worked sporadically for about 2 years. Then in 2000 they decided to "fix" it. That took the system out of commission for about 3 months. For 2-3 months it was impossible to obtain any certified LCAs to file an H-1. Then, finally, about 2 years after it first came into existence, it started working properly and now it is possible to obtain an LCA almost instantaneously via a web based filing system, however, that took nearly 4 years to get working correctly.
The difference in complexity between an LCA (form ETA-9035) and an LC (forms ETA-750A and ETA-750B) is enormous and I consequently do not have much hope that PERM will function effectively anytime in the foreseeable future. I hope that I am wrong.