New NJDOL Comments Are Online

About 1,200 missing comments from New York Life are now uploaded, along with one additional comment that was also missing.

The New Jersey Department of Labor & Workforce Development has uploaded the missing public comments from New York Life about the proposed independent-contractor rule.

You can find them by following these steps. The newly uploaded comments are in the same link that the Labor Department originally put online, and that originally included five PDFs. Clicking on that same link now lets you download additional PDFs.

The new PDF “part six” is the New York Life comments. It includes two form letters followed by lists of all the people who sent each form letter. These lists appear to include about 1,200 names total, which is what a New York Life spokesperson previously told me there would be.

Here are the two New York Life form letters, which the Labor Department says were blocked by a State Department of Homeland Security email security filter:

Deborah Carlin Comment

There is also now a “part seven” PDF uploaded to the Labor Department’s website. It includes one additional public comment, from Deborah Carlin of Monmouth County.

Carlin is a member of the grassroots coalition that I co-founded, Fight For Freelancers. After I learned about the missing New York Life comments, I asked all of the coalition’s members to verify that their comments were included in the process.

We could not find Carlin’s comment in the PDFs that the Labor Department originally uploaded, so I re-sent that comment to the Labor Department yesterday and asked for help locating it.

The Labor Department did not reply to my original email, but it did respond to a followup email today, informing me that Carlin’s comment was included in the new upload. I replied one minute later, asking why Carlin’s comment was originally left out of the process, and I did not receive a response.

Here is Carlin’s three-page comment in full:

It’s Still 99% Opposed

These additional estimated 1,200 public comments, when added to the estimated 8,300 public comments the Labor Department released on September 4, bring the total number of estimated public comments to about 9,500.

I am still only aware of 26 comments in support of the proposed independent-contractor rule. I published a list of those 26 comments with downloadable PDFs and links to read them here.

With the new estimate of about 9,500 total public comments that the Labor Department received, there would have to be about 95 such comments to achieve even 1% support for New Jersey’s proposed independent-contractor rule.