The National Employment Law Project (NELP) and other signatories to this letter submit these comments on the proposed rulemaking regarding the executive, professional and administrative exemptions to overtime under the Fair Labor Standards Act (FLSA).  The National Employment Law Project is a non-profit law office that advocates on behalf of low-income workers and the unemployed.  For over 25 years, NELP has worked with state and local advocates around the country, including legal services offices, community groups, and labor organizations to achieve strong workplace protections and access to government systems of support for low-wage workers and the unemployed. In addition, NELP has a long history of litigation and policy advocacy on a broad range of issues, including job training, employment discrimination, unemployment compensation, the employment rights of workfare participants, the Family and Medical Leave Act, and the FLSA.

The other signatories to this letter include individual academics and lawyers and organizations with a wide experience working with lower-income workers who would be adversely affected by the proposed regulations.  A listing of those signatories is at the end of these comments.

NELP, the signatories, and their constituents have a direct and sustained interest in continued strict enforcement of a national hours-of-work standard and the narrow application of FLSA exemptions which is essential to coverage of low-wage workers who comprise a disproportionate and growing share of the workforce.