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Testimony: 

Before the Subcommittee on Insular Affairs, Oceans and Wildlife, 
Committee on Natural Resources, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Tuesday, May 19, 2009: 

Commonwealth Of The Northern Mariana Islands: 

Coordinated Federal Decisions and Additional Data Are Needed to Manage 
Potential Economic Impact of Applying U.S. Immigration Law: 

Statement of David Gootnick, Director:
International Affairs and Trade: 

GAO-09-426T: 

[End of section] 

Madame Chairwoman and Members of the Subcommittee: 

Thank you for the opportunity to discuss our work on factors that will 
affect the potential economic impact of implementing the legislation 
applying U.S. immigration law to the Commonwealth of the Northern 
Mariana Islands (CNMI).[Footnote 1] 

Although subject to most U.S. laws, the CNMI has administered its own 
immigration system since 1978, under the terms of its 1976 Covenant 
with the United States. The CNMI has applied this flexibility to admit 
substantial numbers of foreign workers[Footnote 2] through a permit 
program for non-U.S. citizens (noncitizens) entering the CNMI. In 2005, 
these workers represented a majority of the CNMI labor force and 
outnumbered U.S. citizens in most industries, including garment 
manufacturing and tourism, which have been central to the CNMI's 
economy. The CNMI also has admitted tourists under its own entry permit 
and entry permit waiver programs and has provided various types of 
admission to foreign investors. As we have reported previously, the 
CNMI faces serious economic challenges, including the decline of 
garment manufacturing and fluctuations in tourism.[Footnote 3] 

The recent immigration legislation amends the U.S.-CNMI Covenant to 
establish federal control of CNMI immigration and includes several 
provisions affecting foreign workers and investors in the CNMI during a 
transition period that ends in 2014. The Secretary of Homeland Security 
decided to delay the start of the transition period for 180 days, from 
June 1, 2009, to November 28, 2009, as allowed under the law in 
consultation with the Secretaries of the Interior, Labor, and State, 
the Attorney General, and the CNMI Governor.[Footnote 4] Unless 
otherwise noted, "transition period" refers to the period beginning 
November 28, 2009, and ending on December 31, 2014. During the 
transition period, the Secretary of Homeland Security, in consultation 
with the Secretaries of the Interior, Labor, and State, as well as the 
Attorney General, are responsible for establishing, administering, and 
enforcing a transition program to regulate immigration in the CNMI. 
[Footnote 5] This program will provide foreign workers temporary 
permits to work in the CNMI (CNMI-only work permits); the number of 
these permits must be reduced to zero by the end of the transition 
period or the end of any extensions of the CNMI-only work permit 
program. The legislation also establishes a joint visa waiver program 
by adding the CNMI to an existing visa waiver program for Guam 
visitors. The legislation's stated intent is to ensure effective border 
control procedures and protect national and homeland security, while 
minimizing the potential adverse economic and fiscal effects of phasing 
out the CNMI's own foreign worker permit program and while maximizing 
the CNMI's potential for economic and business growth. (See attachment 
I for a summary of the legislation's provisions with regard to foreign 
workers, tourists, and investors in the CNMI.)  

My remarks today will summarize findings from our report, issued in 
August 2008, examining factors that will affect the potential impact of 
the legislation's implementation on the CNMI's labor market, 
particularly foreign workers; on its tourism sector; and on foreign 
investment in the CNMI.[Footnote 6] Our report also included 
recommendations to the heads of the agencies responsible for 
implementing the legislation. We conducted the performance audit for 
our August 2008 report from June 2007 to August 2008 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives.[Footnote 7] 

Summary: 

The potential impact of the legislation's implementation on the CNMI's 
labor market, and therefore on its economy, will largely depend on 
decisions that the U.S. Departments of Homeland Security (DHS) and 
Labor (DOL) make in implementing the CNMI-only work permit program. DHS 
will decide on the number of permits to allocate each year, the 
distribution of the permits, their terms and conditions, and the permit 
fees; DOL will decide whether and when to extend the CNMI-only permit 
program past 2014. The interaction of the rate and timing with which 
DHS reduces the available number of permits and the timing of any DOL 
extensions of the program will significantly impact the availability of 
foreign workers; however, we reported in August 2008 that federal 
agencies had not yet identified an interagency process to coordinate 
these decisions. Although modest reductions in CNMI-only permits for 
foreign workers would cause minimal impact, any substantial and rapid 
decline in the availability of CNMI-only work permits would have a 
negative effect on the economy, given foreign workers' prominence in 
key CNMI industries. However, because key federal sources of labor 
market data do not cover the CNMI, the agencies may have difficulty 
obtaining the data needed to make decisions. At the same time, the 
decline in the garment industry, challenges to the tourism industry, 
and the scheduled increases in the minimum wage may reduce demand for 
foreign workers, lessening any potential adverse impact of the 
legislation on the CNMI's economy. 

Any impact of the legislation on the CNMI's tourism sector will depend 
largely on DHS decisions about the countries to be included in the 
joint CNMI-Guam visa waiver program. The legislation's impact will be 
minimal for tourists from countries included in the joint visa waiver 
program. However, increases in costs and time associated with obtaining 
visitor visas, likely for countries not included in the joint program, 
could influence tourists from those countries to choose destinations 
other than the CNMI. At present, most CNMI tourists are from Japan and 
South Korea, both of which will probably be included in the joint visa 
waiver program because they currently are included in the Guam visa 
waiver program. China and Russia are currently not included in the Guam 
visa waiver program and are excluded under a DHS interim final rule for 
the joint visa waiver program; they are therefore most likely to be 
affected by the legislation. They account, respectively, for about 10 
percent and less than 1 percent of CNMI tourist arrivals but are 
nevertheless considered important markets. If China and Russia are not 
included in the joint visa waiver program, tourists from these 
countries will face increased visa fees, more time-consuming 
procedures, and uncertainties related to possible visa refusal. 

The legislation's potential impact on CNMI foreign investment will 
depend, in part, on key DHS decisions regarding foreign investor entry 
permits; however, lack of data makes it difficult to assess the likely 
impact of these decisions and may hamper federal decisions. In 
implementing the legislation, DHS will decide whether to grant holders 
of several types of CNMI foreign investor permits "grandfathered" 
status as U.S. nonimmigrant treaty investors during the transition 
period. DHS also will decide how long the grandfathered status will be 
valid. Although available CNMI data suggest that DHS's decision 
regarding the application of grandfathered status will partly determine 
the impact of the legislation, critical data--showing, for instance, 
current overall foreign investment and amounts associated with each 
type of permit--are not available. This lack of critical data makes it 
difficult to estimate the legislation's likely impact and limits DHS's 
ability to make informed decisions regarding the grandfathered status. 

In our August 2008 report, we recommended that the Secretary of 
Homeland Security lead other relevant federal agencies, including the 
Departments of the Interior, Labor, and State, in identifying the 
interagency process that they will use to coordinate their decisions-- 
and consult with the CNMI government as required[Footnote 8]--in 
jointly implementing the legislation. We also recommended that the 
Secretaries of Homeland Security and Labor jointly develop strategies 
for obtaining critical data on the CNMI labor market and on CNMI 
foreign investment. 

Prior to our August 2008 issuance, we provided a draft of our report to 
officials in DHS, DOI, DOL, and in the CNMI government for review and 
comment and received written comments on the draft report from DHS and 
DOI and from the CNMI government.[Footnote 9] At that time, DHS agreed 
with our findings and recommendations, and DOI generally agreed with 
our findings. The CNMI government raised concerns or issues about some 
aspects of our report methodology and analysis and expressed concern 
that the report's discussion of possible consequences to the CNMI 
economy could itself harm the CNMI. We believe our methodology is a 
sound approach for analyzing the potential impact of federal 
implementation decisions on the CNMI economy. Moreover, we believe that 
reporting the key decisions facing federal agencies and illustrating 
the range of those decisions' potential impacts on the CNMI economy is 
essential to effective implementation of the legislation. 

Legislation's Potential Impact on CNMI Labor Market: 

Decisions that DHS and DOL must make in implementing the CNMI-only work 
permit program will largely determine the legislation's potential 
impact on the availability of foreign workers and, as a result, on the 
CNMI labor market and economy. Under the legislation, DHS is to decide 
on the number of CNMI-only work permits to allocate each year, the 
distribution of the permits, the terms and conditions of the permit 
program, and the fee for the permit.[Footnote 10] DOL will decide 
whether to extend the CNMI-only work permit program, based on the 
unemployment rates of foreign workers and U.S. citizens, as well as 
other CNMI-specific data.[Footnote 11] (See attachment II for a summary 
of the agencies' key implementation decisions.) 

* Number of permits. The number of CNMI-only work permits that will be 
available each year of the initial transition period will depend on the 
strategy that DHS adopts for reducing CNMI-only permits to zero. For 
example, if DHS uses a linear strategy--reducing the permits by the 
same number each year--the number of permits will decline by about half 
by the midpoint of the initial transition period. In contrast, DHS may 
apply a strategy that reduces the number of permits modestly or even 
minimally by the midpoint of the initial transition period. (See 
attachment III for illustrations of alternative DHS decisions regarding 
the annual reduction in CNMI-only work permits.)

* Distribution of permits. The method that DHS chooses to distribute 
the CNMI-only work permits will also affect employers' access to 
workers, particularly if demand for the permits exceeds the supply. For 
example, DHS could decide to distribute the permits through a lottery 
or to distribute the permits among certain industries according to some 
measure of those industries' importance to the CNMI economy. 

* Terms and conditions of the permit program. The terms and conditions 
that DHS sets for the CNMI-only work permit program will affect 
employers' access to foreign workers. For example, any requirements 
regarding workers' skill levels or qualifications could limit the pool 
of available workers. 

* Permit fee. The fee that DHS sets for the CNMI-only work permit may 
affect access to foreign workers. If DHS sets a higher fee for the CNMI-
only permit than the annual fee of $250 that employers currently pay 
for CNMI foreign worker permits, this will increase employers' costs 
and reduce employers' ability or incentive to hire foreign workers. 

* Extension of the permit program. A decision by the Secretary of Labor 
to extend the CNMI-only work permit program past 2014 would maintain 
access to the permits for up to 5 years at a time. Alternately, the 
Secretary may decide not to extend the program, thus ending access to 
CNMI-only work permits after 2014. 

The legislation requires DHS and DOL to coordinate their implementation 
of the legislation, including the CNMI-only work permit program, with 
one another and with other relevant agencies. However, we reported in 
August 2008 that although DOI convened an interagency meeting to 
discuss coordination of the legislation's implementation, the agencies 
had not yet identified the interagency process that they will use. 

In addition, to minimize any potential adverse economic effects of 
implementing the legislation, DHS and DOL will need to consider up-to- 
date information about the CNMI labor market, such as data on the 
wages, occupations, and employment status of CNMI residents and foreign 
workers. However, the agencies may have difficulty in obtaining these 
data because the federal sources generally used to generate such data 
for the United States, including the Current Population Survey and the 
Current Employment Statistics program, do not cover the CNMI.[Footnote 
12] 

The interaction of the rate and timing with which DHS lowers the 
available number of permits with the timing of any DOL extensions of 
the program will significantly affect the permits' availability. For 
example, if DHS lowers the annual allocation of CNMI-only permits by 
the same number each year (a linear decline) and DOL extends the 
program every 2 years, the number of permits will decline less rapidly 
than if DOL extends the program every 4.5 years.[Footnote 13] 
Alternatively, if DHS decides not to substantially decrease the number 
of CNMI-only permits until the last month of the 5-year period and DOL 
extends the program every 2 years, the number of permits will never 
rapidly decline, and by 2028, will not have substantially declined. 
(See attachment IV for illustrations of the potential joint effects of 
alternative DHS and DOL decisions regarding the CNMI-only work permit 
program.) 

The rate at which the availability of CNMI-only work permits for 
foreign workers declines as a result of DHS's and DOL's decisions will 
partly determine the legislation's impact on the CNMI labor market and, 
therefore, on the CNMI's economy. Because of foreign workers' 
prominence in the CNMI labor market, any substantial and rapid 
reduction in the number of CNMI-only permits for foreign workers would 
have a negative effect on the size of the CNMI economy. However, 
federal agencies may make more modest reductions in CNMI-only permits, 
resulting in minimal effects on the economy. To illustrate a range of 
possible impacts on the CNMI economy given varying rates of reduction 
in the number of available CNMI-only work permits, we generated 
simulations that estimate the impact on the CNMI's economy. Attachment 
V presents the results of these simulations, based on several of the 
scenarios shown in attachment IV.[Footnote 14] 

Although U.S. agencies' implementation of the legislation may reduce 
the availability of foreign workers, possible lower demand for these 
workers may lessen the economic impact of any such reduction. The 
decline of the garment industry and challenges to the tourism industry 
have contributed to a drop in the number of foreign workers in the 
CNMI;[Footnote 15] since the elimination of textile quotas in 2005, all 
garment factories in the CNMI have closed, with the last factory closed 
as of February 2009. In addition, the tourism sector has faced 
challenges as visitor arrivals have declined from historic levels. Any 
further declines in these sectors would likely result in reduced demand 
for foreign workers. Moreover, ongoing scheduled increases in the 
CNMI's minimum wage are likely to further reduce the demand for foreign 
workers.[Footnote 16] 

The CNMI has begun efforts to prepare CNMI residents to replace foreign 
workers, which, if successful, could lessen any impact of the 
legislation's implementation on access to foreign workers. In addition, 
the federal legislation requires the U.S. government to provide funding 
for vocational education, as well as technical assistance, to the CNMI. 
[Footnote 17] Although it is too early to assess the CNMI's efforts to 
replace foreign workers with CNMI residents, a number of factors may 
limit the effectiveness of these efforts. For instance, according to 
CNMI government representatives, some CNMI residents are leaving the 
CNMI for opportunities in the United States. Moreover, the number of 
nonworking residents who might accept a job is less than the total 
number of foreign workers. 

Legislation's Potential Impact on CNMI Tourism Sector: 

Any impact of the legislation on the CNMI's tourism sector will depend 
largely on federal regulations specifying the countries to be included 
in the joint CNMI-Guam visa waiver program.[Footnote 18] DHS, in 
consultation with the Department of State, DOI, and the Governors of 
the CNMI and Guam, will decide on the countries to be included in the 
joint CNMI-Guam visa waiver program.[Footnote 19] We reported in August 
2008 that because both Japan and South Korea were part of the Guam visa 
waiver program, they will likely be included in the joint CNMI-Guam 
program. Currently, approximately 80 percent of tourists visiting the 
CNMI come from Japan (55 percent) and South Korea (25 percent). We also 
reported that a key DHS decision would be whether to include China and 
Russia, which are not part of the existing Guam visa waiver program, in 
the joint CNMI-Guam visa waiver program. Tourists from China and Russia 
account for a smaller proportion of the overall CNMI tourist arrivals-
-approximately 10 percent and less than 1 percent of CNMI tourist 
arrivals, respectively. However, according to representatives of the 
CNMI tourism sector, China and Russia are considered important markets 
because of their recent and potential future growth. On January 16, 
2009, DHS issued an interim final rule for the CNMI-Guam joint visa 
waiver program that includes Japan and South Korea and excludes Russia 
and China, citing political, security, and law enforcement concerns, 
including high nonimmigrant visa refusal rates. DHS has not yet issued 
a final rule.[Footnote 20] 

For tourists from countries not included in the joint CNMI-Guam visa 
waiver program, the legislation will likely increase the costs and time 
associated with obtaining visitor visas. For example, if China is not 
included in the program, visa fees could add close to 20 percent to 
tour package costs for Chinese tourists, and in-person visa interviews 
will impose additional inconvenience and cost. To the extent that 
increased costs and time in obtaining a visa may influence tourists to 
choose destinations other than the CNMI, the legislation could have a 
negative impact on CNMI tourism. However, the likely impact on the CNMI 
of sharing the joint program with Guam is unclear. 

Legislation's Potential Impact on CNMI Foreign Investment: 

The impact of the legislation on CNMI foreign investment will depend, 
in part, on DHS decisions regarding foreign investor entry permits. In 
implementing the legislation, DHS will make two key decisions that will 
affect foreign investors' access to the CNMI (see attachment II). 
First, DHS will determine which current CNMI foreign investors will 
receive the grandfathered CNMI-only U.S. treaty investor status during 
the transition period. In particular, DHS will determine whether the 
grandfathered status applies only to investors holding the CNMI 
perpetual foreign investor entry permit or also to investors holding 
the CNMI long-term business entry permit.[Footnote 21] Second, DHS will 
determine the validity period of the grandfathered treaty investor 
status and decide whether to extend it past the initial transition 
period.[Footnote 22] 

If DHS restricts the grandfathering of foreign investors to perpetual 
foreign investor entry permit holders, available CNMI data suggest that 
a small number of investors will qualify for grandfathering under the 
new legislation. However, if DHS extends the grandfathering provision 
to long-term business entry permit holders, many more investors will 
qualify. 

CNMI data show that of 562 long-term business and perpetual foreign 
investor entry permits active and valid in July 2008, perpetual foreign 
investor entry permits accounted for about 10 percent (56 permits) and 
were associated with 30 businesses, and long-term business entry 
permits accounted for 90 percent (506) and were associated with 448 
businesses. 

A lack of key data on foreign investment in the CNMI makes it difficult 
to determine any economic impact of this and other implementation 
decisions and limits DHS's ability to make informed decisions regarding 
the grandfathering of foreign investors. Neither the CNMI government 
nor the federal government has complete data on the overall level of 
foreign investment in the CNMI, which are needed as a baseline for 
assessing the impact of key agency decisions on foreign investment. 
[Footnote 23] In addition, the CNMI government lacks readily accessible 
and compiled data on the sizes and types of permit holders' 
investments, which DHS needs to determine the relative importance of 
each type of entry permit and the likely impact of possible 
implementation decisions. Also unavailable are data showing the extent 
to which foreign investors' decisions are currently affected by their 
access to particular entry permits. 

Concluding Remarks and Prior Recommendations: 

Given the serious challenges already facing the CNMI economy, it is 
critical that federal agencies implement the legislation in ways that 
minimize potential adverse effects to the CNMI economy and maximize the 
CNMI's potential for economic and business growth, following the 
legislation's stated intent. Because the interaction of key federal 
decisions involving different departments will have a significant 
impact on the CNMI economy, coordination of these decisions is critical 
and necessitates an established interagency process, which did not 
exist as of our August 2008 report. In addition, developing strategies 
for obtaining critical data that are unavailable on the CNMI labor 
market and foreign investment is essential to federal agencies' ability 
to make appropriate and effective decisions in implementing the 
legislation and fulfilling its goals. 

Because of the importance of federal agencies' key implementation 
decisions and the interaction of those decisions, our August 2008 
report recommended that the Secretary of Homeland Security lead other 
relevant federal agencies, including the Departments of the Interior, 
Labor, and State, in identifying the interagency process that will be 
used to collaborate with one another--and consult with the CNMI 
government, as required--to jointly implement the legislation. 

In addition, because current data gaps limit federal agencies' ability 
to make key implementation decisions to best meet the goals of the 
legislation, we recommended that the Secretary of Homeland Security and 
the Secretary of Labor: 

* develop a strategy for obtaining critical data on the CNMI labor 
market that are not currently available on an ongoing basis, such as 
data on the wages, occupations, and employment status of CNMI residents 
and foreign workers; and: 

* develop a strategy for obtaining critical data on CNMI foreign 
investment, such as overall levels of foreign investment and the 
investment amounts associated with various types of foreign investor 
entry permits. 

DHS agreed with our recommendations in its written comments, and DOL 
had no comments. 

Madame Chairwoman, this completes my prepared statement. I would be 
happy to respond to any questions you or other Members of the 
Subcommittee may have at this time. 

[End of section] 

Attachment I: Federal Immigration Legislation's Provisions for Foreign 
Workers, Tourists, and Foreign Investors in the Commonwealth of the 
Northern Mariana Islands (CNMI): 

Figure: Illustration of timeline: 

[Refer to PDF for image] 

Enactment of legislation: May 8, 2008; 
Transition period start date November 28, 2009; 
End of initial transition period: 2014. 

Foreign workers: 

CNMI-only work permit program: May be extended indefinitely for up to 5 
years at a time by the U.S. Secretary of Labor. 

Exemptions from certain visa caps for nonimmigrant workers: Begins with 
transition period start date and ends December 31, 2014, under P.L. 110-
229, enacted May 8, 2008. 

Option to apply for nonimmigrant worker visas generally available under 
U.S. law: Begins with transition period start date and continues 
permanently. 

Option to apply for employment-based permanent immigration status 
generally available under U.S. law: Begins with transition period start 
date and continues permanently. 

Tourists: 

Joint CNMI-Guam visa waiver program: Begins with transition period 
start date and continues permanently. 

Option to apply for U.S. visitor visas for business or pleasure 
generally available under U.S. law: Begins with transition period start 
date and continues permanently. 

Foreign investors: 

Option for current CNMI foreign investors to convert to U.S. CNMI-only 
nonimmigrant treaty investors: Begins with transition period start date 
and ends December 31, 2014, under P.L. 110-229, enacted May 8, 2008. 

Option to apply for nonimmigrant treaty investor status generally 
available under U.S. law: Begins with transition period start date and 
continues permanently. 

Option to apply for U.S. immigrant foreign investor status generally 
available under U.S. law: Begins with transition period start date and 
continues permanently. 

Source: GAO analysis of P.L. 110-229 and current U.S. immigration law. 

[End of section] 

Attachment II: Key Federal Implementation Decisions Related to CNMI 
Foreign Workers, Tourism, and Foreign Investors: 

Key federal implementation decisions related to CNMI foreign workers: 

Key federal implementation decisions: Secretary of Homeland Security; 
* Determine the number of permits to provide under the CNMI-only work 
permit program; 
* Determine the way the permits are distributed; 
* Determine the terms and conditions for the permits; 
Legislative requirements and authorizations: 
Reduce annual allocation of CNMI-only permits to zero by the end of the 
transition period or any extensions of the CNMI-only permit program; 
Attempt to promote the maximum use of U.S. citizens and, if needed, 
lawful permanent residents and citizens of the Freely Associated 
States, and to prevent adverse effects on the wages and working 
conditions of those workers. 

Key federal implementation decisions: Secretary of Homeland Security; 
* Determine fees to charge employers and workers for CNMI-only work 
permits; 
Legislative requirements and authorizations: 
Set fees for the permits so as to recover the full cost of providing 
services, including administrative costs; Charge employers an annual 
supplemental fee of $150 per permit to fund CNMI vocational education. 

Key federal implementation decisions: Secretary of Labor; 
Decide whether and when to extend the CNMI-only permit program past 
2014 (indefinitely, for up to 5 years at a time); 
Legislative requirements and authorizations: 
Base decision on the labor needs of legitimate businesses in the CNMI; 
May consider (1) workforce studies on the need for foreign workers, (2) 
the unemployment rate of U.S. citizen workers in the CNMI, and (3) the 
number of unemployed foreign workers in the CNMI, as well as other 
information related to foreign worker trends; Consult with DHS, DOI, 
Department of Defense, and the Governor of the CNMI. 

Key federal implementation decisions related to CNMI tourism: 

Key federal implementation decisions: Secretary of Homeland Security; 
Determine countries to include in the CNMI-Guam visa waiver program, in 
consultation with the Department of State, DOI, and the Governors of 
the CNMI and Guam; 
Legislative requirements and authorizations: 
Shall include any country from which the CNMI has received a 
significant economic benefit from the number of visitors for pleasure 
for the prior year, unless the country's inclusion would pose a 
security threat; Governors of the CNMI and Guam may petition to have 
countries added. 

Key federal implementation decisions related to CNMI foreign investors: 

Key federal implementation decisions: Secretary of Homeland Security; 
Determine which current CNMI foreign investors will be "grandfathered" 
as U.S. E-2 treaty investors when the transition period begins; 
Legislative requirements and authorizations: 
May provide grandfathered status to those who were admitted to the CNMI 
in long-term investor status under CNMI immigration laws before the 
transition program start date, who maintain the investment(s) that 
formed the basis for such status, and who meet other requirements. 

Key federal implementation decisions: Secretary of Homeland Security; 
Decide the validity period for the grandfathered treaty investor 
status; 
Legislative requirements and authorizations: [Empty]. 

Source: GAO analysis of P.L. 110-229, Consolidated Natural Resources 
Act of 2008, May 8, 2008. 

Notes: During the transition period, the Secretary of Homeland 
Security, in consultation with the Secretaries of the Interior, Labor, 
and State, and the Attorney General, has the responsibility to 
establish, administer, and enforce a transition program to regulate 
immigration in the CNMI. 

On January 16, 2009, DHS issued an interim final rule for the CNMI-Guam 
joint visa waiver program. DHS has not yet issued a final rule. 

The legislation does not clearly define what constitutes a "significant 
economic benefit." 

[End of table] 

[End of section] 

Attachment III: Illustrations of Alternative Department of Homeland 
Security Decisions Regarding Annual Reductions in CNMI-Only Work 
Permits for Foreign Workers (3 lines graphs): 

Linear: Reduces the permits at a constant rate to zero: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 17,751; 
December 2010: 14,201; 
December 2011: 10,651; 
December 2012: 7,100; 
December 2013: 3,550; 
December 2014: 0. 

Increasing rate: Increases the rate of reduction over the period to 
zero: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,540; 
December 2010: 18,056; 
December 2011: 15,301; 
December 2012: 11,273; 
December 2013: 5,974; 
December 2014: 0. 

Last Month: Slight decline until sharp drop in last month to zero: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,684; 
December 2010: 19,449; 
December 2011: 19,217; 
December 2012: 18,988; 
December 2013: 18,761; 
December 2014: 0. 

Source: GAO analysis of CNMI Labor and Immigration Identification and 
Documentation System (LIIDS) data. 

Notes: Figures show numbers of CNMI-only work permits for foreign 
workers after the beginning of the transition period, assuming that the 
transition period begins on June 1, 2009, and that the number of 
available CNMI-only work permits never increases. Our analysis does not 
address the duration of the permits' validity, which DHS will 
determine. Although our analysis assumed that the transition period 
begins on June 1, 2009, the delay of the start date to November 28, 
2009, does not affect the general findings of our analysis. 

For the number of foreign workers before and at the beginning of the 
transition period, we relied on CNMI Labor and Immigration 
Identification and Documentation System (LIIDS) data showing 19,823 
706K foreign worker permits active as of December 31, 2007; commenting 
on a draft of our August 2008 report, the CNMI government stated that 
the number of 706K permits as of June 30, 2008, was 18,942. 

In this analysis, foreign workers shown after the beginning of the 
transition period on June 1, 2009, are those with CNMI-only work 
permits; this analysis does not include any foreign workers allowed to 
remain in the CNMI without a CNMI-only work permit. The legislation 
specifies that foreign workers legally present in the CNMI as of the 
transition program effective date, but who do not obtain U.S. 
immigration status, may continue residing and working in the CNMI for a 
limited time--2 years after the effective date of the transition 
program or when the CNMI-issued permit expires, whichever is earlier. 

[End of section] 

Attachment IV: Illustrations of Potential Department of Homeland 
Security and Department of Labor Decisions' Joint Effects on Access to 
CNMI-Only Work Permits for Foreign Workers: 

Nine line graphs indicating: 

Department of Homeland Security decisions about the rate of reduction 
of CNMI-only permits in three manners: Linear; Increasing rate; and 
last Month. 

Plotted against: 

Department of Labor decisions about whether and when to extend CNMI-
only permit program: in three timeframes: Every 2 years; Every 4.5 
years; and, No extension. 

Linear Rate: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: Every 2 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 17,751; 
December 2010: 14,201; 
December 2011: 11,393; 
December 2012: 9,114; 
December 2013: 7,311; 
December 2014: 5,849; 
December 2015: 4,679; 
December 2016: 3,509; 
December 2017: 2,807; 
December 2018: 2,105; 
December 2019: 1,684; 
December 2020: 1,263; 
December 2021: 1,010; 
December 2022: 758; 
December 2023: 606; 
December 2024: 454; 
December 2025: 363; 
December 2026: 272; 
December 2027: 218; 
December 2028: 163. 

Linear Rate: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: Every 4.5 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 18,047; 
December 2010: 14,793; 
December 2011: 11,242; 
December 2012: 7,692; 
December 2013: 4,142; 
December 2014: 3,214; 
December 2015: 2,583; 
December 2016: 1,963; 
December 2017: 1,343; 
December 2018: 723; 
December 2019: 289; 
December 2020: 227; 
December 2021: 165; 
December 2022: 41; 
December 2023: 25; 
December 2024: 19; 
December 2025: 13; 
December 2026: 7; 
December 2027: 2; 
December 2027: 1. 

Linear Rate: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: No extension: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 17,751; 
December 2010: 14,201; 
December 2011: 10,651; 
December 2012: 7,100; 
December 2013: 3,550; 
December 2014: 1; 
December 2015: 1; 
December 2016: 1; 
December 2017: 1; 
December 2018: 1; 
December 2019: 1; 
December 2020: 1; 
December 2021: 1; 
December 2022: 1; 
December 2023: 1; 
December 2024: 1; 
December 2025: 1; 
December 2026: 1; 
December 2027: 1; 
December 2028: 1. 

Increasing Rate: Department of Labor decisions about whether and when 
to extend CNMI-only permit program: Every 2 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,606; 
December 2010: 18,228; 
December 2011: 17,090; 
December 2012: 15,889; 
December 2013: 14,897; 
December 2014: 13,851; 
December 2015: 13,296; 
December 2016: 11,634; 
December 2017: 11,169; 
December 2018: 9,773; 
December 2019: 9,382; 
December 2020: 8,209; 
December 2021: 7,881; 
December 2022: 6,896; 
December 2023: 6,620; 
December 2024: 5,792; 
December 2025: 5,560; 
December 2026: 4,865; 
December 2027: 4,671; 
December 2028: 4,087. 

Increasing Rate: Department of Labor decisions about whether and when 
to extend CNMI-only permit program: Every 4.5 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,606; 
December 2010: 18,228; 
December 2011: 15,579; 
December 2012: 11,658; 
December 2013: 6,944; 
December 2014: 6,684; 
December 2015: 6,417; 
December 2016: 5,615; 
December 2017: 4,278; 
December 2018: 2,406; 
December 2019: 1,257; 
December 2020: 1,155; 
December 2021: 952; 
December 2022: 647; 
December 2023: 241; 
December 2024: 231; 
December 2025: 202; 
December 2026: 154; 
December 2027: 86; 
December 2028: 45. 

Increasing Rate: Department of Labor decisions about whether and when 
to extend CNMI-only permit program: No extension: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,664; 
December 2009: 18,392; 
December 2010: 15,848; 
December 2011: 12,033; 
December 2012: 6,946; 
December 2013: 587; 
December 2014: 1; 
December 2015: 1; 
December 2016: 1; 
December 2017: 1; 
December 2018: 1; 
December 2019: 1; 
December 2020: 1; 
December 2021: 1; 
December 2022: 1; 
December 2023: 1; 
December 2024: 1; 
December 2025: 1; 
December 2026: 1; 
December 2027: 1; 
December 2028: 1. 

Last Month: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: Every 2 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,684; 
December 2010: 19,449; 
December 2011: 19,217; 
December 2012: 18,988; 
December 2013: 18,761; 
December 2014: 18,537; 
December 2015: 18,316; 
December 2016: 18,097; 
December 2017: 17,881; 
December 2018: 17,668; 
December 2019: 17,457; 
December 2020: 17,249; 
December 2021: 17,043; 
December 2022: 16,840; 
December 2023: 16,639; 
December 2024: 16,440; 
December 2025: 16,050; 
December 2026: 15,858; 
December 2027: 15,669; 
December 2028: 15,669. 

Last Month: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: Every 4.5 years: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,684; 
December 2010: 19,449; 
December 2011: 19,217; 
December 2012: 18,988; 
December 2013: 18,761; 
December 2014: 18,537; 
December 2015: 18,298; 
December 2016: 18,079; 
December 2017: 17,864; 
December 2018: 17,650; 
December 2019: 17,440; 
December 2020: 17,232; 
December 2021: 17,026; 
December 2022: 16,823; 
December 2023: 16,622; 
December 2024: 16,424; 
December 2025: 16,228; 
December 2026: 16,034; 
December 2027: 15,843; 
December 2028: 15,669. 

Last Month: Department of Labor decisions about whether and when to 
extend CNMI-only permit program: No extension: (Number of foreign 
workers) 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,684; 
December 2010: 19,449; 
December 2011: 19,236; 
December 2012: 19,007; 
December 2013: 18,780; 
December 2014: 18,556; 
December 2015: 1; 
December 2016: 1; 
December 2017: 1; 
December 2018: 1; 
December 2019: 1; 
December 2020: 1; 
December 2021: 1; 
December 2022: 1; 
December 2023: 1; 
December 2024: 1; 
December 2025: 1; 
December 2026: 1; 
December 2027: 1; 
December 2028: 1. 

Notes: The thin lines represent DOL's decision to extend the CNMI-only 
permit program every 2 years, the heavy gray lines represent DOL's 
decision to extend the program every 4.5 years, and the heavy black 
lines represent DOL's decision not to extend the program. We selected 
the frequency of DOL extensions to be 4.5 years in order to reflect an 
extension just before permits would have been reduced to zero at the 
end of the 5-year period. 

Figures show numbers of CNMI-only work permits, based on the 
assumptions that the transition period begins on June 1, 2009, and the 
number of permits never increases. Our analysis does not address the 
length of the permits' validity. Although our analysis assumed that the 
transition period begins on June 1, 2009, the delay of the start date 
to November 28, 2009, does not affect the general findings of our 
analysis. 

For the number of foreign workers before and at the beginning of the 
transition period, we relied on CNMI LIIDS data showing 19,823 706K 
foreign worker permits active as of December 31, 2007; commenting on a 
draft of our August 2008 report, the CNMI government stated that the 
number of 706K permits as of June 30, 2008, was 18,942. 

In this analysis, foreign workers shown after the beginning of the 
transition period on June 1, 2009, are those with CNMI-only work 
permits; this analysis does not include any foreign workers allowed to 
remain in the CNMI without a CNMI-only work permit. The legislation 
specifies that foreign workers legally present in the CNMI as of the 
transition program effective date, but who do not obtain U.S. 
immigration status, may continue residing and working in the CNMI for a 
limited time--2 years after the effective date of the transition 
program or when the CNMI-issued permit expires, whichever is earlier. 

Although DOL may extend the program for 5 years or less at a time, our 
analysis assumes a 5-year duration for any extensions occurring after 
the transition period. Our analysis also assumes that if the program is 
extended after the end of the initial transition period, the timing for 
frequency of extensions will begin in January 2015. 

The figures extend through 2028 to show the year in which CNMI-only 
work permits approach zero for the majority of the joint decisions. 

[End of section] 

Attachment V: Examples of Scenarios Illustrating U.S. Agency Decisions' 
Potential Joint Impact on Access to CNMI-Only Work Permits for Foreign 
Workers and CNMI Gross Domestic Product: 

As the scenarios in the figure below demonstrate, a greater decline in 
permits for foreign workers leads to a larger drop in gross domestic 
product (GDP), as well as a greater range of possible effects across 
the simulations. 

* Scenario 1 shows that a steep decline in CNMI-only permits for 
foreign workers, from about 20,000 to about 1,000 by 2021[Footnote 24]-
-caused by a linear reduction in the number of CNMI-only work permits 
and a renewal of the permit program every 2 years--would lower the 
CNMI's GDP to a range of about 21 percent to 73 percent of its current 
value by 2021. 

* Scenario 2 shows that a less precipitous decline in CNMI-only permits 
for foreign workers, from about 20,000 to about 8,000 by 2021--caused 
by an increasing reduction in the number of CNMI-only work permits and 
a renewal of the permit program every 2 years (before the years with 
the steepest decline in foreign workers)--would lower the CNMI's GDP to 
a range of about 64 percent to 85 percent of its current value by 2021. 

* Scenario 3 shows that a much smaller decline in CNMI-only permits for 
foreign workers, from about 20,000 to about 17,000 by 2021--caused by a 
rapid reduction in the number of CNMI-only permits in the last month of 
the program and a renewal of the permit program every 2 years (before 
the month when the greatest reduction in permits occurs)--would lower 
the CNMI's GDP to a range of about 98 percent to no less than about 92 
percent of its current value by 2021. 

Figure: Department of Labor decision to extend CNMI-only permit program 
every two years: 

[Refer to PDF for image: Six line graphs]  

Plotting: 

Department of Homeland Security decisions about the rate of reduction 
of CNMI-only permits (Linear, Increasing rate, and Last month): 

Against: 

Department of Labor decision to extend CNMI-only permit program every 
two years. Each of three scenarios depicts number of foreign workers 
and GDP index. The GDP index is depicted as representing: 1) bounds of 
the maximum value; 2) 25th to 75% percentile of results; and 3) bounds 
of the minimum value. 

Over a timeframe of December 2007 through December 2021. 

Department of Labor decision to extend CNMI-only permit program every 
two years: Scenario 1: 

Department of Homeland Security decisions about the rate of reduction of 
CNMI-only permits, Linear: 

Foreign workers: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 17,752; 
December 2010: 14,201; 
December 2011: 11,393; 
December 2012: 9,114; 
December 2013: 7,311; 
December 2014: 5,849; 
December 2015: 4,679; 
December 2016: 3,509; 
December 2017: 2,807; 
December 2018: 2,105; 
December 2019: 1,684; 
December 2020: 1,263; 
December 2021: 1,010; 

GDP Index: 

December 2007: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2008: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2009: 
Bounds of the minimum value: 94-96%; 
25th to 75th percentile of results: 96-97%; 
Bound of the maximum value: 97-98%. 

December 2010: 
Bounds of the minimum value: 84-88%; 
25th to 75th percentile of results: 88-91%; 
Bound of the maximum value: 91-95%. 

December 2011: 
Bounds of the minimum value: 75-82%; 
25th to 75th percentile of results: 82-86%; 
Bound of the maximum value: 86-91%. 

December 2012: 
Bounds of the minimum value: 68-75%; 
25th to 75th percentile of results: 75-81%; 
Bound of the maximum value: 81-87%. 

December 2013: 
Bounds of the minimum value: 61-69%; 
25th to 75th percentile of results: 69-76%; 
Bound of the maximum value: 76-83%. 

December 2014: 
Bounds of the minimum value: 55-64%; 
25th to 75th percentile of results: 64-72%; 
Bound of the maximum value: 72-80%. 

December 2015: 
Bounds of the minimum value: 50-60%; 
25th to 75th percentile of results: 60-69%; 
Bound of the maximum value: 69-79%. 

December 2016: 
Bounds of the minimum value: 43-55%; 
25th to 75th percentile of results: 55-65%; 
Bound of the maximum value: 65-77%. 

December 2017: 
Bounds of the minimum value: 38-51%; 
25th to 75th percentile of results: 51-62%; 
Bound of the maximum value: 62-76%. 

December 2018: 
Bounds of the minimum value: 33-48%; 
25th to 75th percentile of results: 48-59%; 
Bound of the maximum value: 59-74%. 

December 2019: 
Bounds of the minimum value: 29-44%; 
25th to 75th percentile of results: 44-57%; 
Bound of the maximum value: 57-74%. 

December 2020: 
Bounds of the minimum value: 25-41%; 
25th to 75th percentile of results: 41-54%; 
Bound of the maximum value: 54-73%. 

December 2021: 
Bounds of the minimum value: 22-38%; 
25th to 75th percentile of results: 38-52%; 
Bound of the maximum value: 52-72%. 

Department of Labor decision to extend CNMI-only permit program every 
two years: Scenario 2: 

Department of Homeland Security decisions about the rate of reduction 
of CNMI-only permits, Increasing rate: 

Foreign workers: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,606; 
December 2010: 18,228; 
December 2011: 17,090; 
December 2012: 15,889; 
December 2013: 14,897; 
December 2014: 13,851; 
December 2015: 13,296; 
December 2016: 11,634; 
December 2017: 11,169; 
December 2018: 9,773; 
December 2019: 9,382; 
December 2020: 8,209; 
December 2021: 7,881; 

GDP Index: 

December 2007: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2008: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2009: 
Bounds of the minimum value: 99.4-99.6%; 
25th to 75th percentile of results: 99.6-99.7%; 
Bound of the maximum value: 99.7-99.8%. 

December 2010: 
Bounds of the minimum value: 95.6-96.8%; 
25th to 75th percentile of results: 96.8-97.7%; 
Bound of the maximum value: 97.7-98.7%. 

December 2011: 
Bounds of the minimum value: 92.5-94.5%; 
25th to 75th percentile of results: 94.5-95.9%; 
Bound of the maximum value: 95.9-97.6%. 

December 2012: 
Bounds of the minimum value: 89.1-92%; 
25th to 75th percentile of results: 92-94%; 
Bound of the maximum value: 94.9-96.4%. 

December 2013: 
Bounds of the minimum value: 86.3-89.8%; 
25th to 75th percentile of results: 89.8-92.3%; 
Bound of the maximum value: 92.3-95.4%. 

December 2014: 
Bounds of the minimum value: 83.3-87.5%; 
25th to 75th percentile of results: 87.5-90.5%; 
Bound of the maximum value: 90.5-94.2%. 

December 2015: 
Bounds of the minimum value: 81.6-86.2%; 
25th to 75th percentile of results: 86.2-89.5%; 
Bound of the maximum value: 89.5-93.5%. 

December 2016: 
Bounds of the minimum value: 75.6-82.1%; 
25th to 75th percentile of results: 82.1-86.4%; 
Bound of the maximum value: 86.4-91.2%. 

December 2017: 
Bounds of the minimum value:75.1-80.9%; 
25th to 75th percentile of results: 80.9-85.4%; 
Bound of the maximum value: 85.4-90.5%. 

December 2018: 
Bounds of the minimum value: 70.7-77.2%; 
25th to 75th percentile of results: 77.2-82.6%; 
Bound of the maximum value: 82.6-88.2%. 

December 2019: 
Bounds of the minimum value: 69.4-76.1%; 
25th to 75th percentile of results: 76.1-81.7%; 
Bound of the maximum value: 81.7-87.5%. 

December 2020: 
Bounds of the minimum value: 65.5-72.7%; 
25th to 75th percentile of results: 72.7-78.0%; 
Bound of the maximum value: 78.0-85.2%. 

December 2021: 
Bounds of the minimum value: 64.3-71.7%; 
25th to 75th percentile of results: 71.7-78.2%; 
Bound of the maximum value: 78.2-84.6%. 

Department of Labor decision to extend CNMI-only permit program every 
two years: Scenario 3: 

Department of Homeland Security decisions about the rate of reduction 
of CNMI-only permits, Last month: 

Foreign workers: 

December 2007: 19,823; 
December 2008: 19,823; 
December 2009: 19,684; 
December 2010: 19,449; 
December 2011: 19,217; 
December 2012: 18,988; 
December 2013: 18,761; 
December 2014: 18,537; 
December 2015: 18,316; 
December 2016: 18,097; 
December 2017: 17,881; 
December 2018: 17,668; 
December 2019: 17,457; 
December 2020: 17,249; 
December 2021: 17,043; 

GDP Index: 

December 2007: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2008: 
Bounds of the minimum value: 100%; 
25th to 75th percentile of results: 100%; 
Bound of the maximum value: 100%. 

December 2009: 
Bounds of the minimum value: 99.6-99.7%; 
25th to 75th percentile of results: 99.7-99.8%; 
Bound of the maximum value: 99.8-99.9%. 

December 2010: 
Bounds of the minimum value: 98.9-99.3%; 
25th to 75th percentile of results: 99.3-99.5%; 
Bound of the maximum value: 99.5-97.7%. 

December 2011: 
Bounds of the minimum value: 98.3-98.8%; 
25th to 75th percentile of results: 98.8-99.1%; 
Bound of the maximum value: 99.1-99.5%. 

December 2012: 
Bounds of the minimum value: 97.6-98.4%; 
25th to 75th percentile of results: 98.4-98.8%; 
Bound of the maximum value: 98.8-99.3%. 

December 2013: 
Bounds of the minimum value: 97.0-97.9%; 
25th to 75th percentile of results: 97.9-98.5%; 
Bound of the maximum value: 98.5-99.1%. 

December 2014: 
Bounds of the minimum value: 96.4-97.5%; 
25th to 75th percentile of results: 97.5-98.1%; 
Bound of the maximum value: 98.1-98.9%. 

December 2015: 
Bounds of the minimum value: 95.7-97.0%; 
25th to 75th percentile of results: 97.0-97.8%; 
Bound of the maximum value: 97.8-98.7%. 

December 2016: 
Bounds of the minimum value: 955.1-96.6%; 
25th to 75th percentile of results: 96.6-97.5%; 
Bound of the maximum value: 97.5-98.5%. 

December 2017: 
Bounds of the minimum value:94.5-96.2%; 
25th to 75th percentile of results: 96.2-97.2%; 
Bound of the maximum value: 97.2-98.4%. 

December 2018: 
Bounds of the minimum value: 93.9-95.7%; 
25th to 75th percentile of results: 95.7-96.8%; 
Bound of the maximum value: 96.8-98.2%. 

December 2019: 
Bounds of the minimum value: 93.3-95.3%; 
25th to 75th percentile of results: 95.3-96.5%; 
Bound of the maximum value: 96.5-97.9%. 

December 2020: 
Bounds of the minimum value: 92.7-94.9%; 
25th to 75th percentile of results: 94.9-96.2%; 
Bound of the maximum value: 96.2-97.8%. 

December 2021: 
Bounds of the minimum value: 92.1-94.5%; 
25th to 75th percentile of results: 94.5-95.9%; 
Bound of the maximum value: 95.9-97.6%. 

Notes: This analysis is based on some of the possible joint effects of 
DHS and DOL decisions illustrated in attachment IV (A), (D), and (G). 
Because this analysis does not allow for other changes in the CNMI over 
the coming years, it should not be considered as predictive of future 
GDP. 

In the graphs on the left-hand side of each scenario, the lines 
represent the reduction in the numbers of CNMI-only work permits for 
foreign workers. The graphs on the right-hand side of each scenario 
represent 10,000 simulations of the CNMI GDP (indexed to be 100 in 
2007) under various assumptions. The darker area represents the middle 
50 percent of results, specifically the 25th to 75th percentile, while 
the lighter area represents the bounds of the minimum and maximum 
value. 

This analysis assumes that technology, capital, and the total number of 
employed CNMI residents remain constant. In addition, this analysis 
treats all foreign workers as being employed in full-time positions. 
Further, this analysis does not reflect potential changes in demand for 
foreign workers absent the legislation. Finally, this analysis does not 
account for the role of foreign workers under programs other than the 
CNMI-only permit program. See appendix VI of GAO-08-791 for more 
details. 

In this analysis, foreign workers shown after the beginning of the 
transition period on June 1, 2009, are those with CNMI-only work 
permits; this analysis does not include any foreign workers allowed to 
remain in the CNMI without a CNMI-only work permit. The legislation 
specifies that foreign workers legally present in the CNMI as of the 
transition program effective date, but who do not obtain U.S. 
immigration status, may continue residing and working in the CNMI for a 
limited time--2 years after the effective date of the transition 
program or when the CNMI-issued permit expires, whichever is earlier. 
Although our analysis assumed that the transition period begins on June 
1, 2009, the delay of the start date to November 28, 2009, does not 
affect the general findings of our analysis. 

Because of the nature of the functional form used, we could not use it 
to evaluate the portion of those scenarios in which the number of CNMI- 
only work permits is equal to zero. 

[End of figure] 

[End of section] 

Attachment VI: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

For more information regarding this testimony, please contact David 
Gootnick at (202) 512-3149 or gootnickd@gao.gov, or Tom McCool at (202) 
512-2642 or mccoolt@gao.gov. 

Staff Acknowledgments: 

In addition to the contacts named above, Emil Friberg (Assistant 
Director); Mark Speight (Assistant General Counsel); Ashley Alley; 
Diana Blumenfeld; Benjamin Bolitzer; Ming Chen; Keesha Egebrecht; 
Marissa Jones; Reid Lowe; Mary Moutsos; and Eddie Uyekawa made key 
contributions to this testimony. Technical assistance was provided by 
Shirley Brothwell, Holly Dye, Etana Finkler, Michael Hoffman, Michael 
Kendix, Rhiannon Patterson, Nina Pfeiffer, Diahanna Post, Jeremy 
Sebest, Berel Spivack, and Seyda Wentworth. 

[End of section] 

Footnotes: 

[1] Consolidated Natural Resources Act of 2008, Pub. L. No. 110-229, 
Title VII, 122 Stat. 754, 853 (May 8, 2008). 

[2] In this testimony, "foreign workers" refers to workers in the CNMI 
who are not U.S. citizens or U.S. lawful permanent residents. Other 
sources sometimes call these workers "nonresident workers," "guest 
workers," "noncitizen workers," "alien workers," or "nonimmigrant 
workers." We do not use the term to refer to workers from the Freely 
Associated States--the Federated States of Micronesia, Republic of the 
Marshall Islands, and Republic of Palau--who are permitted to work in 
the United States, including the CNMI, under the Compacts of Free 
Association (48 U.S.C. § 1901 note, 1921 note, and 1931 note). 

[3] For a list of related products, see GAO, Commonwealth of the 
Northern Mariana Islands: Managing Potential Economic Impact of 
Applying U.S. Immigration Law Requires Coordinated Federal Decisions 
and Additional Data, [hyperlink, 
http://www.gao.gov/products/GAO-08-791] (Washington, D.C.: Aug. 4, 
2008). 

[4] The Secretary of Homeland Security announced the delay of the 
transition period on March 31, 2009. 

[5] The legislation requires the Secretary of Homeland Security, in 
consultation with the Secretaries of the Interior, Labor, and State, 
and the Attorney General, to negotiate and implement interagency 
agreements to identify and assign their respective duties for timely 
implementation of the transition program. The agreements must address 
procedures to ensure that CNMI employers have access to adequate labor 
and that tourists, students, retirees, and other visitors have access 
to the CNMI without unnecessary obstacles. Some federal decisions 
require consultation with the CNMI Governor. In addition, the 
legislation requires the CNMI government to provide the Secretary of 
Homeland Security all immigration records or other information that the 
Secretary deems necessary to assist its implementation. 

[6] GAO, Commonwealth of the Northern Mariana Islands: Managing 
Potential Economic Impact of Applying U.S. Immigration Law Requires 
Coordinated Federal Decisions and Additional Data, [hyperlink, 
http://www.gao.gov/products/GAO-08-791] (Washington, D.C.: Aug. 4, 
2008). This report was based on our March 2008 review of the then 
pending legislation, which was signed into law on May 8, 2008. See GAO, 
Commonwealth of the Northern Mariana Islands: Pending Legislation Would 
Apply U.S. Immigration Law to the CNMI with a Transition Period, 
[hyperlink, http://www.gao.gov/products/GAO-08-466] (Washington, D.C.: 
Mar. 28, 2008). 

[7] See GAO-08-791, appendix I, for a full description of our report's 
scope and methodology. 

[8] Decisions requiring consultation with the CNMI Governor include, 
among others, whether to delay the start date of the transition period 
by up to 180 days and which countries to include in the CNMI-Guam visa 
waiver program. 

[9] See [hyperlink, http://www.gao.gov/products/GAO-08-791] for a 
fuller description of the agencies' and the CNMI's written comments and 
our response; reproductions of DHS's, DOI's, and the CNMI government's 
comments appear in appendixes X, XI, and XII, respectively. DHS, DOI, 
and the CNMI government also provided technical comments regarding our 
August 2008 report, which we incorporated in the report as appropriate. 

[10] The legislation instructs DHS to reduce annual allocation of CNMI- 
only permits to zero by the end of the transition period or any 
extensions of the CNMI-only permit program; attempt to promote the 
maximum use of U.S. citizens and, if needed, lawful permanent residents 
and citizens of the Freely Associated States, and attempt to prevent 
adverse effects on the wages and working conditions of those workers; 
and set fees for the permits so as to recover the full cost of 
providing services, including administrative costs, by charging 
employers an annual supplemental fee of $150 per permit to fund CNMI 
vocational education. 

[11] According to the legislation, DOL may extend the program 
indefinitely for up to 5 years at a time. DOL may issue the extension 
as early as desired within the transition period and up to 180 days 
before the end of the transition period or any extensions of the CNMI- 
only permit program. The legislation instructs DOL to base its decision 
on the labor needs of legitimate businesses in the CNMI. To determine 
these needs, DOL may consider (1) workforce studies on the need for 
foreign workers, (2) the unemployment rate of U.S. citizen workers in 
the CNMI, and (3) the number of unemployed foreign workers in the CNMI, 
as well as other information related to foreign worker trends. In 
addition, DOL is to consult with DHS, DOI, the Department of Defense, 
and the Governor of the CNMI. 

[12] U.S. Department of Labor, Office of the Assistant Secretary for 
Policy, Impact of Increased Minimum Wages on the Economies of American 
Samoa and the Commonwealth of the Northern Mariana Islands (Washington, 
D.C., 2008). DOI's Office of Insular Affairs has provided technical 
assistance to the CNMI to help with data collection, including funding 
for the 2005 Household, Income, and Expenditures Survey (HIES) and past 
surveys of the CNMI. However, this assistance has not generated the 
scope of data collected by federal sources for the United States more 
generally. 

[13] We selected the frequency of DOL extensions to be 4.5 years in 
order to reflect an extension just before permits would have been 
reduced to zero at the end of the 5-year period. 

[14] Because these simulations do not allow for other changes in the 
CNMI over the coming years, they should not be considered as predictive 
of future GDP. Rather, these simulations are intended to illustrate a 
range of potential impacts on the CNMI's GDP that could result from 
some of the joint U.S. agency decisions depicted in attachment IV. 

[15] From 2000 to 2005, the number of noncitizen workers, many of whom 
are foreign workers, dropped from about 35,000 in 2000 to about 28,000 
in 2005, and we reported in August 2008 that CNMI data showed that the 
number of foreign workers had continued to fall. 

[16] Until 2007, the CNMI's workforce was subject to a minimum wage set 
by the CNMI government. At the beginning of 2007, the CNMI's minimum 
wage was $3.05 per hour, substantially lower than the U.S. federal 
minimum wage of $5.15 per hour but higher than wages for comparable 
positions in China, the Philippines, Vietnam, and other Asian 
countries. In 2007, Congress enacted the U.S. Troop Readiness, 
Veterans' Care, Katrina Recovery, and Iraq Accountability 
Appropriations Act, gradually increasing the CNMI minimum wage until it 
meets federal minimum wage requirements, Pub. L. No. 110-28, § 8103, 
121 Stat. 188 (May 25, 2007). The American Recovery and Reinvestment 
Act of 2009 mandates that GAO issue a study in April 2010 of past and 
future minimum wage increases in the CNMI and American Samoa, and in 
each year thereafter, until the minimum wages in the insular areas 
reach $7.25 per hour. 

[17] For example, the $150 fee charged to employers obtaining a CNMI- 
only work permit is to be used to fund ongoing vocational education 
curricula and program development by CNMI educational entities. 
Moreover, the legislation requires the Secretary of the Interior to 
provide technical assistance to the CNMI to promote economic growth; to 
assist employers in recruiting, training, and hiring U.S. citizens and, 
if necessary, lawful permanent residents in the CNMI; and to develop 
CNMI job skills as needed. 

[18] The joint visa waiver program exempts tourism and business 
visitors from certain countries who are traveling to the CNMI and Guam 
for up to 45 days from the standard U.S. visa documentation 
requirements. One stated intent of the legislation is to expand tourism 
and economic development in the CNMI, including aiding prospective 
tourists in gaining access to the CNMI's tourist attractions, such as 
memorials, beaches, parks, and dive sites. 

[19] The legislation required DHS to identify countries within 180 days 
of enactment of the legislation, by November 4, 2008. The countries 
shall include any country from which the CNMI has received a 
significant economic benefit from the number of visitors for pleasure 
for the prior year, unless the country's inclusion would pose a 
security threat. Governors of the CNMI and Guam may petition to have 
countries added. 

[20] 74 Fed. Reg. 2824-02 (2009). The rule also states that DHS will 
determine whether nationals of China and Russia can participate in the 
CNMI-Guam visa waiver program after additional layered security 
measures, which may include, but are not limited to, electronic travel 
authorization to screen and approve potential visitors to Guam and the 
CNMI, and other border security infrastructure measures. 

[21] The CNMI offers a perpetual foreign investor entry permit, valid 
for an indefinite period of time, to individuals who maintain certain 
levels of investment in the CNMI, among other requirements. In 
addition, the CNMI offers a long-term business entry permit (valid for 
2 years at a time) with specified investment requirements, as well as a 
regular-term business entry permit (valid for up to 90 days) with no 
investment requirements. The CNMI also offers a retiree foreign 
investor entry permit requiring a minimum investment in residential 
property by an applicant 55 years or older; however, because the 
retiree foreign investor entry permit does not require investment in a 
CNMI business, we assume that investors holding this permit will not be 
grandfathered. 

[22] Although the status can be awarded only during the transition 
period, the legislation imposes no limit on the grandfathered status's 
length of validity. If and when the grandfathered status expires, and 
for new CNMI foreign investors, DHS will adjudicate applications under 
the regular treaty investor status and under the other immigrant or 
nonimmigrant categories generally available under U.S. immigration law. 
See GAO-08-466 for more information about the legislation's 
requirements related to foreign investment in the CNMI. 

[23] The U.S. Department of Commerce's Bureau of Economic Analysis 
collects information on foreign direct investments in states and other 
territories, but data for the CNMI are combined with data for other 
territories such as Guam, American Samoa, and the U.S. Virgin Islands. 
In addition, the 2002 Economic Census of the Northern Mariana Islands 
includes information on CNMI businesses by owner citizenship status; 
however, these data are incomplete. 

[24] Because foreign workers comprise 60 percent of the CNMI labor 
market, the decline in these workers shown in scenario 1 would reduce 
total CNMI employment by almost 60 percent. 

[End of section] 

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