August 26th IRAP Deadline
Just a reminder that the IRAP comments are due on or before August 26, 2019
Our primary effort is to encourage our stakeholders (officers, members – especially apprentices, contractors, contractor associations, etc.) to submit written comments to the Department of Labor. The website for filing comments is: https://www.regulations.gov/comment?D=ETA-2019-0005-0001. You can read the text of the rule (if you’re interested) and see other filed comments at this address: https://www.regulations.gov/docket?D=ETA-2019-0005.
The best comments are individualized, rather than form letter. Regulations.gov uses an optical scanner to identify identical comments. The effect of this is that 200 identical letters would be treated as a single comment by DOL. While quantity is important politically, it will not be as effective in rulemaking as a specific comment that DOL has to consider. For your convenience, if you are in a position to help contractors file specific comments as we discussed in Bowie, attached is a one page background sheet for your use and that can be distributed to contractors, and an interview sheet that you can use to interview individual contractors. If contractors are willing to write their own specific comment, the Construction Employers Association (CEA) has developed this helpful guide: https://www.ceacisp.org/protect-construction-apprenticeships
As a last resort, if you are speaking to contractors who are willing to file a comment, but are not inclined to either write their own or participate in an interview and review a ghost-written comment, CEA and the Building Trades have made the following site available for filing form letters: www.protectconstructiontraining.org
For members, IMTEF has provided the attached guide for instructors and apprentices to file individual comments, and BAC has developed this website for filing form letters (as an alternative, but again, individual comments are best): https://www.savebacapprenticeships.org.
Finally, BAC President Jim Boland recorded a video message breaking down the real dangers of this rule, which may be helpful to view and to share: https://youtu.be/8LGPVYwuaY4.
Also, one of the big backers of this bill is the National Center for Construction Education and Research (NCCER). We urge every one of our programs not to use any of their curriculum as we would be contributing to those who want to destroy our apprenticeship programs.