Public Comments

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Richard Jacobs
ETA, OFLC Forms - ETA
OMB control number 1205-0508: public comments
Tuesday, May 26, 2026 12:03:53 PM

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Re: Proposed regulation on prevailing wages - OMB control number 1205-0508
Dear Mr. Pasternak,
Please note that if the prevailing wage floors are moved to higher percentiles, the Department
of Labor will need to revise the guidelines to determine the Wage Levels.
For example, a Wage Level IV may presently be appropriate for a Job Zone 4 position that
requires 5 years’ previous experience, because the prevailing wage floor for Wage Level IV
starts at the 67th percentile. If you move the prevailing wage floor for Wage Level IV to the
88th percentile, the years of experience to trigger 3 points on the prevailing wage analysis will
be higher.
Thank you for your patience and consideration.
Sincerely,
Richard Jacobs
Attorney at Law
P.O. Box 10748
13380 N Madison Ave. NE
Bainbridge Island, WA 98110
Tel: 206 780-1114
Fax: 206 780-1115
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