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AILA letter to DOL, June 13, 2016 - "The American Immigration Lawyers Association (AILA) submits the following comments in response to the Department of Labor’s “Proposed changes to occupation, industry, and area detail in the OES survey,” published on the Bureau of Labor Statistics (BLS) website on May 19, 2016. Though we appreciate the goal of ensuring that BLS resources are utilized in the most efficient manner possible, we have serious concerns about the proposed changes. ... [T]he BLS has now announced this process to change the SOC without formal notice and comment required by the Administrative Procedure Act (APA). Due to the potential negative impacts as explained below, we encourage the BLS to withdraw this proposal and instead incorporate it into the second Federal Register notice regarding potential SOC modifications. ... BLS has proposed the aggregation of a significant number of occupations, ranging from buyers and purchasing agents, to cooks and postsecondary teachers. Although this would reduce the overall number of OES occupations, it would not improve the OES database and would result in less reliable data. Specifically, reducing the number of occupations would have a grave impact on how occupations are defined for various immigration purposes, including DOL’s PERM process and H-1B specialty occupations, as well as determining the appropriate prevailing wage for these occupations. ... "