![](media/image1.jpeg){width="1.5833333333333333in"
height="1.5881944444444445in"}

February 4, 2008

Mr. Thomas M. Dowd, Administrator

Office of Policy Development and Research

U.S. Department of Labor

Washington, D.C. 20210

**[Re: Regulatory Information Number (RIN) 1205-AB50 \~ Apprenticeship
Programs, Labor Standards of Registration, Amendment of
Regulations]{.underline}**

Dear Mr. Dowd:

I am writing on behalf of Washington State Building and Construction
Trades Council to express our grave concerns about the apprenticeship
rulemaking recently undertaken by the U.S. Department of Labor. The
proposed changes will drastically alter the way apprentices are educated
and trained in the building and construction trades in Washington State
by watering down standards to make it easier to undermine successful
state-certified apprenticeship programs operated jointly by labor and
employers through JATCs.

It is our belief that these proposed rule changes have been pushed by
stakeholders who do not completely understand the full implications for
states like Washington that have developed high standards and
substantially increased opportunities for apprentices.

There appears to be an extreme rush to administer these changes; yet
there has been no public outcry for "reforming" apprenticeship. Why is
the DOL rushing to "fix" an established national effort 30 years in the
making, despite no evidence that it is broken? In Washington State [the
number of apprentices has more than doubled in the last five quarters to
over 16,000]{.underline}, approximately 85 percent of these
apprenticeship programs are in construction that have demonstrated the
greatest growth to meet industry workforce needs.

Our Council's comments and concerns to the proposed rule changes in US
DOL (RIN) 1205-AB50 contained in the December 13, 2007 Federal Register
are included as "Attachment A" to [Section I Background]{.underline}
assumptions as rationalization for the proposed changes to 29 CFR Part
29 through rule; "Attachment B" responds to [Section II Section by
Section Analysis]{.underline} contained in this Federal Register.

Page 1 of 2

[(RIN) 1205-AB50]{.underline}

Thomas M. Dowd, U.S. DOL

2.4.08

[Section III Administrative Requirements for Proposed
Rulemaking]{.underline} is addressed throughout all Attachments
reflecting our contentions that these proposed rules will adversely
affect the nation's economy exceeding \$100 million per year, that the
unfunded mandates place unnecessary burdens on state budgets and
planning, and especially that the proposed changes are not in the best
interest to safeguard apprentices and therefore pose a detriment to
apprentices, families and communities.

These changes are far reaching, most of which will not safeguard the
welfare and education of apprentices, nor value the tremendous work
developed in cooperation between employers, labor and government
representatives. We ask that you allow greater time and input to this
important segment of education and training before proceeding with
[any]{.underline} of the proposed changes to current standards and
process. If an extension is granted by the US DOL, we respectfully
request reserving the right to submit additional comments brought to
this Council by our Affiliates during that extension to submit their
remarks as an addendum to this original reply submitted electronically
and mailed by the original February 11, 2008 deadline.

On behalf of the Affiliates of the Washington State Building and
Construction Trades Council, AFL-CIO who have established an historical
record to provide more than a century of apprenticeship opportunities
across the United States, first constructing or original cities and
towns and now to revitalizing livable communities with new technologies
and infrastructures, we submit this cover letter and four attachments as
our remarks for the record to the U.S. Department of Labor's proposed
rule changes to the National Apprenticeship Act (RIN) 1205-AB50 due
February 11, 2008.

Respectfully,

![](media/image2.jpeg){width="2.453472222222222in"
height="1.0666666666666667in"}

David D. Johnson, Executive Secretary

Washington State Building & Construction Trades Council, AFL-CIO

cc: Mark H. Ayers, BCTD President

Bob Pleasure, BCTD Education Director

Mike Callanan, NJATC Executive Director

opeiu23/afl-cio