Employers must currently submit a Labor Certification Agreement (LCA) with the number of workers it will cover.

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From the perspective of resource economics, it is not obvious that LCA is the right tool for regulation.

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It also may only investigate fraud based on a complaint and only after the LCA has been approved.

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Even worse, current law requires the LCA be open to the public, so the new regulation would reveal confidential employee information.

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The agency is only permitted to check the LCA for completeness and obvious inaccuracies (e.g. the wage listed is below the prevailing wage).

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Proponents simply have asserted that policy should be based on LCA, apparently assuming that its utility as a technology assessment tool implies its value as a regulatory tool.

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Emissions inventories are thus tied to real sources rather than to the LCA abstraction of carbon footprint, affording greater clarity to the question of which entities can be reasonably held accountable for what emissions, he argues.

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Although fully establishing this ideal will not be possible initially, climate protection is best served by putting its elements in place from the inception of a policy regime rather than using approaches such as LCA that are poorly grounded in the principles of sound environmental management.

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