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09/04/09 The new proposed H-2A regulations from the Solis Labor Department were published in the Federal Register today. The National Council of Agricultural Employers (NCAE) is doing a legal analysis of the new proposals. Several NCAE H-2A committee members have already read the proposals and the universal comment is “return to pre-Bush only worse" -- with return to 50-percent rule, more penalties, easier to be debarred, and increased role/power of states. NGA will post and distribute detailed analyses as they become available. NCAE can use contributions for further detailed legal analysis and comments. NGA serves on this committee and will participate in developing the NCAE response as well as submitting a response on behalf of NGA. H-2A users are encouraged to join NCAE and/or to make a special contribution to help with this critical legal work on the new proposals. Go to www.NCAEonline.org to join or make a contribution. A $200-$500 contribution would be a big help. The NCAE H-2A Committee will be holding conference calls over the next month to develop comments and responses to the proposals. Any H-2A user who wishes to be part of this should join NCAE and request to be on that committee. This is where the action is on an industry-wide response to the proposed regulations. NCAE will initially request 30 days more comment time (bringing the total to 60 days if granted). To comment on the proposed rules:
Click on the “Submit a Comment” link. Click here to view a pdf of the proposed H-2A regulations
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