We would also like to register our concern regarding the quality of the notice the DOL issued to withdraw the final rule. The DOL bases its economic impact analysis supporting the withdrawal of the final rule on the October 26, 2020, comment on the initial notice of rulemaking authored by Heidi Shierholz at the Economic Policy Institute. We discuss the analytical shortcomings of Shierholz’s comment, and because the DOL incorporates Shierholz’s economic impact analysis into its notice, we provide a reanalysis for comparison in the following section. Our analysis is more firmly anchored in academic labor economics research, and we believe it provides a more accurate picture of the likely effects of withdrawing the final rule.