Philadelphia Regional DOL Tracker - Old (Archived on 09/23/2004)

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07/21/2004: Labor Certification Backlog Reduction Regulation Published Today-Part 3

[[Page 43718]]

In comparison to the universe of all small businesses, the
approximately 186,000 employers with pending applications would
represent at most 0.8 percent of all small businesses [(186,000 )
22,900,000 = 0.008; 0.008 x 100 = 0.8%)]. DOL asserts that 0.8% of
small businesses does not represent a significant proportion of small
entities.
The Department welcomes comments on this RFA certification.
Unfunded Mandates Reform Act of 1995: This interim final rule will
not result in the expenditure by State, local, and tribal governments,
in the aggregate, or by the private sector, of $100 million or more in
any one year, and it will not significantly or uniquely affect small
governments. Therefore, no actions are deemed necessary under the
provisions of the Unfunded Mandates Reform Act of 1995.
Small Business Regulatory Enforcement Fairness Act of 1996: This
interim final rule is not a major rule as defined by section 804 of the
Small Business Regulatory Enforcement Act of 1996 (SBREFA). The
standards for determining whether a rule is a major rule as defined by
section 804 of SBREFA are similar to those used to determine whether a
rule is an ``economically significant regulatory action'' within the
meaning of Executive Order 12866. Because we certified that this
interim final rule is not an economically significant rule under
Executive Order 12866, we certify that it also is not a major rule
under SBREFA. It will not result in an annual effect on the economy of
$100 million or more; a major increase in costs or prices; or
significant adverse effects on competition, employment, investment,
productivity, innovation, or on the ability of United States-based
companies to compete with foreign-based companies in domestic and
export markets.
Executive Order 13132--Federalism: This interim final rule will not
have a substantial direct effect on the States, on the relationship
between the National Government and the States, or on the distribution
of power and responsibilities among the various levels of government.
Therefore, in accordance with Executive Order 13132, we have determined
that this interim final rule does not have sufficient federalism
implications to warrant the preparation of a summary impact statement.
Assessment of Federal Regulations and Policies on Families: This
interim final rule does not affect family well-being.
Paperwork Reduction Act: The collection of information under part
656 is currently approved under OMB control number 1205-0015. This
interim final rule does not include a substantive or material
modification of that collection of information, because it will not add
to or change paperwork requirements for employers applying for
permanent labor certification, but rather creates a means for
consolidated processing at centralized locations. Accordingly, the
Department believes the Paperwork Reduction Act is inapplicable to this
interim final rule. The Department invites the public to comment on its
Paperwork Reduction Act analysis.
Publication as an Interim Final Rule: The Department has determined
that it is unnecessary and contrary to the public interest to publish
this technical amendment to the permanent labor certification
regulations as a Notice of Proposed Rulemaking, with the delays
inherent to the process of publishing a proposed rule, receiving and
reviewing comments, and clearing and publishing a final rule. This
interim final rule will allow ETA's Division of Foreign Labor
Certification to take more rapid action to reduce the serious backlog
in permanent labor certification applications through transfer of
applications from the SWAs and ETA Regional Offices to centralized
processing sites. This processing change is based on results of a pilot
program that demonstrated that centralized processing would create
economic and time-saving efficiencies and speed reduction of the
backlog. Centralized processing will not alter substantive requirements
for certification. It will not impose an additional burden on employers
who have filed permanent labor certification applications or on the
immigrant aliens on whose behalf applications have been filed. Rather,
centralized processing is expected to benefit applicants by reducing
anticipated processing time. For these reasons, it would be contrary to
the public interest, as well as unnecessary; to delay implementation of
this technical regulatory amendment to establish centralized processing
procedures. Therefore, the Department finds pursuant to 5 U.S.C.
553(b)(3)(B) that good cause exists for publishing this regulatory
amendment as an interim final rule. While notice of proposed rulemaking
is being waived, the Department is interested in comments and advice
regarding this interim final rule.
Catalogue of Federal Domestic Assistance Number: This program is
listed in the Catalog of Federal Domestic Assistance at Number 17.203,
``Labor Certification for Alien Workers.''

List of Subjects in 20 CFR Part 656

Administrative practice and procedure, Agriculture, Aliens,
Crewmembers, Employment, Employment and training, Enforcement, Forest
and forest products, Fraud, Guam, Health professions, Immigration,
Labor, Longshore and harbor work, Migrant labor, Passports and visas,
Reporting and recordkeeping requirements, Students, Unemployment,
Wages, and Working conditions.

0
For the reasons stated in the Preamble, the Employment and Training
Administration, Department of Labor, amends 20 CFR part 656 as follows:

PART 656--LABOR CERTIFICATION PROCESS FOR PERMANENT EMPLOYMENT OF
ALIENS IN THE UNITED STATES

0
1. The authority citation for part 656 continues to read as follows:

Authority: 8 U.S.C. 1182(a)(5)(A) and 1182(p); 29 U.S.C. 49 et
seq.; sec. 122, Pub. L. 101-649, 109 Stat. 4978.

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2. Part 656, subpart C, is amended by adding section 656.24a, to be
placed immediately after section 656.24, to read as follows:


Sec. 656.24a Centralized processing.

(a) To facilitate processing of applications and elimination of
backlogs, the National Certifying Officer (Chief, Division of Foreign
Labor Certification) may direct a SWA or an ETA Regional Office to
transfer to a non-State centralized processing site some or all pending
applications filed under part 656. The Chief will issue a directive to
the SWAs and ETA Regional Offices stating how pending applications are
to be identified for centralized processing and where they are to be
transferred. For each transferred application, the centralized
processing site will perform all required functions of the SWA (as
described in Sec. 656.21) and the Regional Certifying Officer (as
described in Sec. 656.21 and Sec. 656.24).
(b) If the labor certification presents a special or unique
problem, the centralized processing site, in consultation with or at
the direction of the National Certifying Officer, may refer the
application to the National Certifying Officer for determination. If
the National Certifying Officer has directed that certain types of
applications or specific applications be handled in the national
office, the centralized processing site shall refer such applications
to the National Certifying Officer.


[[Page 43719]]


Signed at Washington, DC, this 13th day of July, 2004.
Emily Stover DeRocco,
Assistant Secretary, Employment and Training Administration.
[FR Doc. 04-16536 Filed 7-20-04; 8:45 am]

BILLING CODE 4510-30-P
 
singhna said:
Hey How_long,

is Your case in RIR or non RIR? I am also in the August group.

Looks like Philly DOL guys are all on vacation or something.
It is RIR. I know two people from my company there DOL receipt date was July 2003 and they were approved in September 2003.
 
Well, FINALLY some good news about the backlog. I was pleasantly surprised that they decided on a 30 day period instead of the 3 month period which I had expected.

This has both direct and indirect benifits: The direct one obviously being the the fact that a bunch of 2003 LC will be sent to the new center. The indirect benifit is that once they have decided which ones to send over, the existing DOL center can start working on the remaining cases. I guess we'll see LCs being certified in parallel - old ones sent over and ones after the cut-off date.

Still, the proof of the pudding is in the eating, and we'll see when the first regular cases (aug 2003, no NOF, remand etc) are actually certified.
 
Cut off date?

Well, FINALLY some good news about the backlog. I was pleasantly surprised that they decided on a 30 day period instead of the 3 month period which I had expected.

Sorry I did not read all the details. Is there a cut off date as to how and which applications to be sent to the soon to operate backlog centers? Thanks.
 
meg_z said:
Sorry I did not read all the details. Is there a cut off date as to how and which applications to be sent to the soon to operate backlog centers? Thanks.

The 30 day period refers to the time when it is implemented. Normally, any policy/undertaking can be implemented within a 3 month period after it is published in the federal register. As a result, most of the time they set a date of implementation which is just under 3 months. In this case, they set a target date of 30 days for making the new centers operational, which is much less than the 90 day period they could have potentially availed of.

The cut-off date in my post referred to the last receipt date of LC which will be transferred to the new centers. It might be Dec 2003, or any other date. Of course I'm assuming that selection of LC appilcations to be sent over to the new centers will be chronological.
 
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So what does this imply. Does this mean that LC processing times will be reduced..will it effect those whose LC was applied in May,2004.
 
vpsr254 said:
So what does this imply. Does this mean that LC processing times will be reduced..will it effect those whose LC was applied in May,2004.
This announcement affects everyone with an outstanding LC. Pineapples point is that the announcement indicates that certain cases will be transferred to the new backlog center (say Dec 2003 through to today) and the remainder would stay with DOL. However we don't know what that cut off date will be. Could be Dec 2003, could be Jun 2003 could be Mar 2004.

Which basket you then fall into (backlog center/DOL regional office) will then be a lottery to see which one process through things and how quickly and how many with RFE's or denials......new phase of uncertainty until we see what the results start turning out like.

It will be interesting to see if they also make any splits for RIR versus Non RIR too.

Frankly until they start operating or a mole from Philly DOL starts to squeek to us we will just have to sit back, wait and see what occurs. At least there will be a significant additional pool of people processing the applications and we will finally see some movement.

Keep your fingers crossed everyone.
 
Backlog Reduction Centers

these BRC's are going to handle how many states...? If Philly BRC is going to handle 10-15 states and process both State and Labor..I doubt that we will see much improvement in the pace at which cases are processed...

Have they mentioned what will be the level of staffing at the BRC's as compared to that at Philly BTW: what is the level of staffing at the Philly Regional Office?
 
Aye there's the rub. No one is quite sure. From what I saw in posts earlier in the month Philly DOL and San Fran were to be the two DOL centers that would receive the initial focus for the BRC's. This is in line with them having the longest wait times currently for RIR and NON RIR. Dallas already has it's special project and Atlanta is the other BRC location.

Wonder how they will do reporting now if they are splitting the outstanding cases. Will they add the BRC's to the monthly statistics list? What will they report? All imponderables.
 
They found my case, since my case was sent to Philly in the same envelope with my colleague's, they did not notice (!) mine! My lawyer has received a fax from Philly stating my case number and my case will be processed with the receipt date of May 24, too.

But as far as I know, our cases will most likely be denied. I do not want to tell you the reason right now, let me wait and see.

stueym said:
Go for it and good luck. I hope you get agood result. If you do let us all know what the outcome is.

Stueym
 
Backlog Reduction Centers

If I read it right, the reductionc centers will take over cases from both state and regional offices. Don't you think it is only fair that they process the files that are already with Regional first? Also, since we have passed the examination from state, the cases already with the regional dol should be approved very fast. Right?
 
VAhoper said:
If I read it right, the reductionc centers will take over cases from both state and regional offices. Don't you think it is only fair that they process the files that are already with Regional first? Also, since we have passed the examination from state, the cases already with the regional dol should be approved very fast. Right?

Well, as you might have heard that they will accept comments/suggestions within next 30 days:

--------------------------
"This interim final rule is effective August 20, 2004. Interested
persons are invited to submit written comments on this interim final
rule. To ensure consideration, comments must be received on or before
August 20, 2004.

ADDRESSES: You may submit comments, identified by Regulatory
Information Number (RIN) 1205-AB37, by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.

Follow the website instructions for submitting comments.
E-mail: Comments may be submitted by e-mail to
blrcomments@dol.gov. Include RIN 1205-AB37 in the subject line of the

message.
Mail: Submit written comments to the Assistant Secretary
for Employment and Training Administration, U.S. Department of Labor,
200 Constitution Avenue, NW., Room C-4312, Washington, DC 20210,
Attention: William Carlson, Chief, Division of Foreign Labor
Certification. Because of security measures, mail directed to
Washington, DC is sometimes delayed. We will only consider comments
postmarked by the U.S. Postal Service or other delivery service on or
before the deadline for comments.
-------------------------------------------

So why don't we all sent a comment/suggestion to them, stating that the regional cases should be processed before state cases. I think its fair because most of us have already waited 2+ years, so we should be the first one to get expedited processing. But they may not realize it, until many of us send comments. This is our oppertunity to speak out.
 
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Just send an email.
Let's do something for ourselves!

msabir said:
Well, as you might have heard that they will accept comments/suggestions within next 30 days:

--------------------------
"This interim final rule is effective August 20, 2004. Interested
persons are invited to submit written comments on this interim final
rule. To ensure consideration, comments must be received on or before
August 20, 2004.

ADDRESSES: You may submit comments, identified by Regulatory
Information Number (RIN) 1205-AB37, by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.

Follow the website instructions for submitting comments.
E-mail: Comments may be submitted by e-mail to
blrcomments@dol.gov. Include RIN 1205-AB37 in the subject line of the

message.
Mail: Submit written comments to the Assistant Secretary
for Employment and Training Administration, U.S. Department of Labor,
200 Constitution Avenue, NW., Room C-4312, Washington, DC 20210,
Attention: William Carlson, Chief, Division of Foreign Labor
Certification. Because of security measures, mail directed to
Washington, DC is sometimes delayed. We will only consider comments
postmarked by the U.S. Postal Service or other delivery service on or
before the deadline for comments.
-------------------------------------------

So why don't we all sent a comment/suggestion to them, stating that the regional cases should be processed before state cases. I think its fair because most of us have already waited 2+ years, so we should be the first one to get expedited processing. But they may not realize it, until many of us send comments. This is our oppertunity to speak out.
 
Lets put in comments

Lets all put in comments. This is the lease we can do for ourselves. Lets stress that we are already in regional office and have waited a long time. Based on the initial filing date (The first filing date with state dol), we should be processed first. Also, since state offices have already processed our cases, our cases should just be granted approval immediately. They are combining the state and regional processing into one step in this backlog reduction effort anyway.

msabir said:
Well, as you might have heard that they will accept comments/suggestions within next 30 days:

--------------------------
"This interim final rule is effective August 20, 2004. Interested
persons are invited to submit written comments on this interim final
rule. To ensure consideration, comments must be received on or before
August 20, 2004.

ADDRESSES: You may submit comments, identified by Regulatory
Information Number (RIN) 1205-AB37, by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.

Follow the website instructions for submitting comments.
E-mail: Comments may be submitted by e-mail to
blrcomments@dol.gov. Include RIN 1205-AB37 in the subject line of the

message.
Mail: Submit written comments to the Assistant Secretary
for Employment and Training Administration, U.S. Department of Labor,
200 Constitution Avenue, NW., Room C-4312, Washington, DC 20210,
Attention: William Carlson, Chief, Division of Foreign Labor
Certification. Because of security measures, mail directed to
Washington, DC is sometimes delayed. We will only consider comments
postmarked by the U.S. Postal Service or other delivery service on or
before the deadline for comments.
-------------------------------------------

So why don't we all sent a comment/suggestion to them, stating that the regional cases should be processed before state cases. I think its fair because most of us have already waited 2+ years, so we should be the first one to get expedited processing. But they may not realize it, until many of us send comments. This is our oppertunity to speak out.
 
How long does it take for the application to move from SWA to DOL

Dear Fellow immigrants,
My attornies say that they have submitted the recruitement report to Philadelphia SWA last month (Non-RIR, EB3). How long does it take these days for the labor application to move from SWA to Philly DOL.
 
Okay so Murthy just confirmed some of the things that I posted earlier. Namely that BRC in Philadelphia and Dallas due to the focus on clearing those Regions backlogs first. See text below:

Locations of Backlog Reduction Centers

As previously indicated in our June 18, 2004 MURTHYBULLETIN article entitled, "Labor Certification Update - 2004" <http://www.murthy.com/news/n_labcer..html>, available on MurthyDotCom, the DOL has stated that there will be two central processing sites. One will be in Philadelphia, PA, and the other will be in Dallas, TX. This backlog reduction plan will only apply to cases filed under the current procedures. The plan will not apply to cases that will be filed under PERM, when the PERM regulation is finalized. It is likely that PERM will not be published until the fall, and it is still expected that the implementation of PERM will not occur until 120 days after the PERM rule is published in the Federal Register.

We do not expect that all cases caught in the backlog will be sent immediately to the central processing sites. The NCO is permitted to send cases to these sites, but is not required to do so. As detailed in the earlier MURTHYBULLETIN article, cited above, the DOL intends to send cases from the Philadelphia and Dallas federal regions to these centers first, followed by cases from the Atlanta and Chicago federal regions. Atlanta, GA and Chicago, IL are also expected to be the two future homes of centralized PERM processing centers. After those case transfers are complete, cases from other regions may be added. Since the NCO has discretion in this matter, however, this plan may change at any time.

Timeframes for Completing Backlog Processing

DOL officials have stated that the goal is to try and complete all LC and RIR backlog processing within 2 years of PERM's implementation. The rule itself, however, does not give a timeline for the completion of processing backlogged cases. The comments on the rule state that "the extent of centralized processing and the speed with which the current backlog will be reduced may vary based upon program priorities." Therefore, it may be some time before we can determine the effectiveness of this system and see any change in processing backlogs of labor certifications and RIR applications for permanent residency.

Murthy.com
 
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