HAFA Adai Delegate Kimberlyn King-Hinds!
We sincerely thank you for reaching out to the Rota Chamber of Commerce for input on the proposed Northern Mariana Islands Labor Stabilization Act. We also appreciate your proactive approach in addressing the upcoming 2029 deadline and taking the initiative to hear the concerns of employers and the workforce across the CNMI. Early engagement on this matter is critical to ensuring long-term economic stability for our islands.
The Chamber supports several key provisions of the proposed Act. In particular:
• Extension of the Labor Stabilization Program beyond 2029, as access to the program remains essential to sustaining the entire CNMI’s workforce and economic stability, especially in more isolated regions such as Rota.
• Elimination of the “touchback” requirement, which has created significant operational and financial strain on both workers and employers. Workforce instability continues to affect small businesses throughout the CNMI, and recent business closures, including the announced July closure of National Office Supply, underscore the importance of stable and predictable labor policies.
• Localization of the employment petition approval process through the Office of the Governor, recognizing that labor needs and economic realities in the CNMI are best evaluated locally.
• Adjustment of the numerical cap to 15,000, with a separate allocation for construction and extraction occupations, providing greater predictability and responsiveness to economic needs.
While we are encouraged by these improvements, we respectfully recommend the following additional considerations:
1) Although the proposed Act calibrates prevailing wages to 75% of the otherwise applicable prevailing wage, the Chamber encourages consideration of removing the prevailing wage requirement altogether. We recognize that prevailing wage standards are intended to ensure fair compensation. Employers already comply with applicable Federal and Commonwealth minimum wage requirements, and we believe that establishing the Federal minimum wage as the statutory baseline would provide consistency while allowing compensation levels to reflect market conditions and competitive workforce realities.
Rota’s small business environment operates on narrow margins, and prevailing wage determinations, regardless of calibration, continue to create financial strain and uncertainty. In practice, employers must offer competitive wages to attract and retain workers, and market dynamics serve as a meaningful safeguard in ensuring fair compensation.
2) The Chamber understands the intent behind the proposed $150 per-petition fee to support enforcement and administrative functions. However, if the prevailing wage requirement remains in place, we respectfully request reconsideration of this additional fee. Small businesses already bear substantial USCIS filing fees and compliance-related expenses. If prevailing wage requirements were removed and employers were permitted to follow the minimum wage standard, businesses would be more willing to absorb the $150 petition fee, as the overall labor cost structure would become more predictable and manageable.
3) With respect to the proposed 15,000 numerical cap, the Chamber recommends consideration of allowing flexibility for the Governor to allocate permits by island based on demonstrated workforce needs. Establishing a reasonable allocation framework could help ensure that each island receives appropriate access to permits reflective of local economic conditions.
In summary, the Chamber supports the extension of the program and many of the solutions the Act proposes, with the above considerations offered.
Thank you again for engaging the Chamber in this discussion and for your continued collaboration with the business community. Please let us know if any additional clarification would be helpful.
Best regards,
ROTA CHAMBER OF COMMERCE
CC: Hon. Aubry M. Hocog, Rota Mayor
