The Department of Labor published in the October 2, 2025 Federal Register its analysis and plans for the H-2A program – seasonal farm labor, for the most part. Farms typically hire workers, almost all from Mexico, for 5 – 8 months, with the season starting in earnest in April. The program attracts workers because they are paid about 10 times what they would get locally in Mexico.

DOL said that farms face persistent labor shortages, especially in labor-intensive, seasonal crops such as fruits, vegetables, and nursery production. It estimates that unauthorized labor  at 42% of crop workers. Trump wants to throw all of them out.

The DOL plan of October calls for more H-2A workers – but not enough. In 2010, about 75,000 workers came in under H-2A; in 2025, about 400,000. DOL predicts about 550,000 in 2030. The math is bad for farmers, even with DOL’s plans for more H-2A workers. That is because an expected rise in H-2A workers (which DOL says requires reforms in the program) is per DOL’s own figures going to make up for only half the unauthorized workers to be removed. The rest, presumably, will come from legal Hispanic workers who are experienced in this work. This suggests a tacit deal that ICE lay off mass deportation of farm workers.

In 2015, the minimum H-2A wage was roughly $11–12 per hour. In 2025 the weighted national average wage had risen $17–$18 per hour, with California near $20. The Dept of Labor expects H-2A wages to increase to $22–$24 per hour by 2030. The average median wage across all occupations in the Bakersfield-Delano labor market was probably about $18 in 2015 and about $25 in 2025.  The bulk of jobs held by Americans are year-round and indoors. Median wages in Mexican areas where H-2A workers come from are about $2 an hour.

Farms which use H-2A must provide free housing. Free housing costs the farm an effective cost of about $5 an hour. DOL plans to create a tiered system for wages. That will not eliminate the very high deferential. It will also create a larger gap between H-2A wages and prevailing wages of Americans in the same market area.