EB2-3 Predictions (Rather Calculations) 2015-2020

From Ron Gotcher's Site http://www.immigration-information.com This is the Post.

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Some Interesting Visa Office Updates

In their most recent conversation with Charlie Oppenheim of the Visa Office, AILA liaison commented, in part, as follows:

EB-2 India.

After advancing 16 months in March 2015, EB-2 India will advance another eight months in April, to September 1, 2007. Members can expect EB-2 India to continue to advance at a steady pace for another couple of months before slowing or holding toward the end of the fiscal year.
. . .
What will it take for there to be movement in EB-3 India?

At this time, there is nothing which can be done to improve the India EB-3 cut-off date situation unless there is a legislative change. The amount of pre-adjudicated India EB-3 demand versus the annual limit prevents more than a one or two week monthly movement of this cut-off date. For example, at this time, more than 9,100 India EB-3 applicants with priority dates earlier than January 1, 2005 (alone) have already been reported to the visa Office and the FY2015 annual limit is approximately 2,875.

Do you foresee EB-3 Worldwide becoming current anytime soon? If so, what would that mean for EB-3 India?

Charlie does not anticipate that EB-3 Worldwide will become current anytime soon but the cut-off date could easily reach 2015. If the Worldwide EB-3 category ever becomes current then (and only then) any "otherwise unused" numbers could be made available to the India EB-3 category, which has the earliest EB-3 cut-off date.

In his Executive Actions on Immigration, President Obama directed DOS and USCIS to work on a system to alleviate the visa backlogs. Have any steps been taken to effectuate the intent of the President?

Yes. One example is having advanced the cut-off dates at a more rapid pace, and much earlier, than in previous years.​


Ron

James Ronald Gotcher
Global Immigration Partners
22775 Malibu Hills Road, Suite 150
Calabasas Hills, CA 91301
Tel: 818-914-6482
Fax: 818-475-3450

Inquiries@GotcherLaw.com

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I'm somewhat surprised by some of those answers.

The Oh Law Firm has this rather brief summary:

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03/18/2015: State Department Prediction of Visa Bulletin Movement Post April 2015

According to the AILA, Mr. Charles Oppenheim predicts the following:

• India EB-2: It will continue to advance at a steady pace for another two months before slow down or holding toards the end of this fiscal year (09/30/2015)
• India EB-3: Just one or two weeks movement per month
• China EB-2: Some movement may be possibe, but should excessive demand takes place, some move-back can be considered.
• China EB-3: Not too promising.
• China EB-5: Retrogession in June or earlier.
• Worldwide EB-3: Another big move ahead in May. However, may not see "current" within this fiscal year.

Overall, somewhat disappointing, but better than regrogression!

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Originally Posted by Spectator

From Ron Gotcher's Site http://www.immigration-information.com This is the Post.



I'm somewhat surprised by some of those answers.

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So basically he is saying no SO for EB 3 I. I am surprised to hear that EB 3 Row will not be current this year. It is already technically current.

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Originally Posted by Spectator

From Ron Gotcher's Site http://www.immigration-information.com This is the Post.



I'm somewhat surprised by some of those answers.

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He is never consistent across his different meetings. Regarding EB3 situation, why is EB3 ROW advancing so fast in the past couple of months if there was demand in that category ? For me it sounds like he is going to waste EB3 visas by not doing FA to EB3I.

This is surprising. There is broad consensus that there isn't much demand left in EB3 for this FY beyond the current PD. Perhaps he is hedging any possibility of greater migration of EB2ROW applications to EB3ROW. Even then, this migrations should not have any appreciable effect in the current FY.

Considering that there is a 5 months left in this FY beyond the Apr VB, I don't see how EB3ROW will not become current. It would be a travesty if CO is late in making EB3ROW current and consequently is late in sending RFEs to EB3I and ends up wasting visa numbers. We are not out of time yet but soon will be there.

Update: Last Inventory: EB1ROW 12.5K, EB2ROW 18K, EB3ROW 8K. There is no way that EB3ROW will not get current this FY without wasting visa numbers.

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Originally Posted by amulchandra

So basically he is saying no SO for EB 3 I. I am surprised to hear that EB 3 Row will not be current this year. It is already technically current.

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Originally Posted by imdeng

This is surprising. There is broad consensus that there isn't much demand left in EB3 for this FY beyond the current PD. Perhaps he is hedging any possibility of greater migration of EB2ROW applications to EB3ROW. Even then, this migrations should not have any appreciable effect in the current FY.

Considering that there is a 5 months left in this FY beyond the Apr VB, I don't see how EB3ROW will not become current. It would be a travesty if CO is late in making EB3ROW current and consequently is late in sending RFEs to EB3I and ends up wasting visa numbers. We are not out of time yet but soon will be there.

Update: Last Inventory: EB1ROW 12.5K, EB2ROW 18K, EB3ROW 8K. There is no way that EB3ROW will not get current this FY without wasting visa numbers.

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May be CO is extremely cautious and doesn't want to make any predictions. In my opinion things might be different as we move closer to the last quarter and he might progress EB3 I dates.

Thanks
Amul

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Originally Posted by amulchandra

May be CO is extremely cautious and doesn't want to make any predictions. In my opinion things might be different as we move closer to the last quarter and he might progress EB3 I dates.

Thanks
Amul

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Is there a possibility that there is demand from consulates for EB3 visas which we are not aware of ?

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Originally Posted by gcq

Is there a possibility that there is demand from consulates for EB3 visas which we are not aware of ?

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I don't think PERM filings show that much excessive demand. So consular processing might not be the case. But I would like to hear from the gurus here what they think.

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Originally Posted by gcq

Is there a possibility that there is demand from consulates for EB3 visas which we are not aware of ?

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gcq,

That's always a possibility, but I have considered the historical % of CP. The figures for ROW are shown below:

FY2014 - 11.70%
FY2013 - 13.08%
FY2012 - 14.27%
FY2011 - 19.21%
FY2010 - 11.70%

Philippines does, historically have very high CP % (40-60%), but the numbers are ultimately limited by reaching the overall 7% limit. Philippines used 5.7k EB3 visas last FY, but possible extra usage in EB2-P this FY suggests that number will not be exceeded, or may be slightly less.

Mexico has ranged from 5-10% CP cases. They've used 3-4k total EB3 visas per FY since the EB3-M COD caught up with ROW. Again, ultimately, EB3-M use is eventually limited by the overall 7% limit.

The November 2014 Immigrant Visa Applicants Report from DOS doesn't suggest anything extraordinary from ROW.

Thanks for the explanation spec, amulchandra

the perm data suggests that there will be less demand for eb3 row 485's than its yearly quota , why is the CO/USCIS/DoS unable to see this ?

That's because (USCIS/DOS) they do a poor job of forecasting. For eg, please look at July 2013 VB, where they predict only 3 weeks movement for EB3I in Q4 but actually there is 8 months movement in Sep 2013 VB as a precedent....

http://travel.state.gov/content/visa...july-2013.html

http://travel.state.gov/content/visa...mber-2013.html

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Originally Posted by ROCK72

That's because (USCIS/DOS) they do a poor job of forecasting. For eg, please look at July 2013 VB, where they predict only 3 weeks movement for EB3I in Q4 but actually there is 8 months movement in Sep 2013 VB as a precedent....

http://travel.state.gov/content/visa...july-2013.html

http://travel.state.gov/content/visa...mber-2013.html

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Exactly that is what I was going to say. Most of the times USCIS is very bad at estimating the demand. They procrastinate a lot till the end of the FY.

Initially I was little disheartened when I saw the AILA update but my past experience says that the gurus here are far better and have a greater understanding about demand estimation than USCIS.

I still think that EB3 I is going to get some reasonable SO this year.

may be uscis inventory due in april will show the reality for eb3row demand. USCIS/CO/DoS have not completely utilized the EB3 quota for past years, hope they wont go waste again this year

My dates became current sometime in august last year. I got the RFE on July 7, and anticipating the RFE, i got everything ready by July 5th. I get the RFE on july 7th and by July 9th, my RFE is received at USCIS. The wait for GC began on 1st of September and i was happy that i have 2 months... guess what, on october 8th they issued me another RFE and that arrived on October 23rd. Exactly the same RFE, medical & letter of employment. My doctor issued the medical again on the same day since it was under 3 month time frame and filed immediately again. October 29th, they changed the status that response is received...... but demise of my hopes, october 31st retrogression hits....

I don't know if it was me being proactive or USCIS being just not doing its job. But take a deep breath and go with the flow. Don't do anything in anticipation.

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Originally Posted by lilstud2007

My PD is 11/11/2009.

Silly question - but would it make sense to do the medical in June/July in anticipation that I will receive the RFE later this year and it can be submitted quickly?

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Spec, Q and Suva,

Appreciate all your feedback.

Spec,

From what you wrote, the only SO to EB2I will be from EB2ROW, EB2M and EB2P. Is that correct? At this point in time, is it possible to narrow-down the SO numbers? I know you said 10k to 15k earlier. Does it look too much now?

Iatiam

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Originally Posted by iatiam

Spec, Q and Suva,

Appreciate all your feedback.

Spec,

From what you wrote, the only SO to EB2I will be from EB2ROW, EB2M and EB2P. Is that correct? At this point in time, is it possible to narrow-down the SO numbers? I know you said 10k to 15k earlier. Does it look too much now?

Iatiam

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Iatam,

I don't really see any reason to change my original thoughts. I wouldn't currently lower the numbers.

EB1 might give some Fall Down, but I don't think it will be much.

EB5 is not going to provide any extra numbers to EB1. That is absolutely clear. EB5-China will become retrogressed within the next 2 VB, meaning all EB5 visas will be used.

In a Murthy article from October 2014, CO said that EB4 was seeing increased demand and that a Cut Off Date might be necessary eventually (but that might be FY2016). EB4 saw a 28.5% increase in approvals in FY2014 to 8.3k compared to FY2013.

I don't currently see EB1 usage being drastically different to that seen in FY2014.

The lower number of unused FB visas available to EB in FY2015 (4k vs 11k in FY2014) means 4k less would be available to EB2-I in FY2015 if the same approval numbers as FY2014 were seen.

EB2-I received about 1.4k more visa numbers in FY2014 than SO allowed. Whether that happens again is open to speculation.

That would already reduce the numbers available to EB2-I from 23.5k to around 18k.

EB2-WW approvals in FY2014 were almost certainly artificially low (22k) in FY2014 due to the corresponding preceding period having very low PERM approvals. PERM approvals have increased (substantially) in the period that are likely to yield FY2015 I-485 approvals for EB2-WW. That is going to lead to higher EB2-WW approvals this year. Based on Trackitt figures, EB2-ROW has already surpassed the number of approvals seen by the end of May last year. Trackitt really doesn't have sufficient information to judge what EB2-MP might be doing. That is despite a considerable slowing of I-485 adjudication times. It's not clear what the final EB2-WW usage might be - it may be subject to external factors outside just the number of pending applications.

Let's just wait and see.

I post this only as a "fun fact", since it is for a single quarter only.

Below shows a comparison of Citizenship vs Birth Country for PERM certification in Q1 FY2015.

------------ Citizenship --- Birth - % Diff
China ------------ 1,305 --- 1,429 -- +9.5%
India ------------ 9,176 --- 9,209 -- +0.4%
Mexico ------------- 299 ----- 295 -- -1.3%
Philippines -------- 307 ----- 316 -- +2.9%
ROW -------------- 5,105 --- 4,943 -- -3.2%

ALL ------------- 16,192 -- 16,192

Perhaps not unsurprisingly, Citizens of Canada appear to be the most likely to have a different Country of Birth. Of 857 cases having a different Country of Birth, 414 had Canadian Citizenship (48%). Of these, 103 were born in China (25%), 65 were born in India (15.5%), 2 were born in Philippines (0.5%) and 244 were born in another ROW Country (59%).

Country of Citizenship data comes from the OFLC Quarterly Disclosure Data.
Country of Birth data comes from PermChecker.com who extract it from the ETA9089

My best stab at a comparison of PERM Certifications between FY2014 and FY2015 for Q2 and H1 (Q1/Q2).

-------------- FY14 Q2 - FY15 Q2 - % of FY14
China ---------- 1,188 --- 1,645 ---- 138%
India ---------- 9,446 -- 12,611 ---- 134%
Mexico ----------- 321 ----- 386 ---- 120%
Philippines ------ 474 ----- 319 ----- 67%
ROW ------------ 5,679 --- 5,217 ----- 92%

ALL ----------- 17,108 -- 20,178 ---- 118%


-------------- FY14 H1 - FY15 H1 - % of FY14
China ---------- 1,829 --- 3,074 ---- 168%
India --------- 14,522 -- 21,820 ---- 150%
Mexico ----------- 602 ----- 681 ---- 113%
Philippines ------ 684 ----- 635 ----- 93%
ROW ------------ 8,535 -- 10,160 ---- 119%

ALL ----------- 26,172 -- 36,370 ---- 139%


This is a comparison of the preceding rolling yearly PERM Certification numbers for the preceding year and this year i.e. Q3 FY2013 to Q2 FY2014 and Q3 FY2014 to Q2 FY2015.

------------- H2FY13/H1FY14 -- H2FY14/H1FY15 - %
China ---------- 2,631 ---------- 5,822 ----- 221%
India --------- 23,099 --------- 42,390 ----- 184%
Mexico ----------- 861 ---------- 1,374 ----- 160%
Philippines ---- 1,056 ---------- 1,453 ----- 138%
ROW ----------- 12,600 --------- 21,792 ----- 173%

ALL ----------- 40,247 --------- 72,831 ----- 181%

Thanks Spec for the report.

The pace of PERM certifications is certainly a downer for EB2I. The EB2ROW 485 approvals also seem to have almost doubled recently as seen from your trackitt comparison thread.

R

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Originally Posted by redwood

Thanks Spec for the report.

The pace of PERM certifications is certainly a downer for EB2I. The EB2ROW 485 approvals also seem to have almost doubled recently as seen from your trackitt comparison thread.

R

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redwood,

Unfortunately, that was always likely to happen, given the PERM certification pattern. Last year's approvals were abnormally low because of that.

On the positive side for EB2-I, the I-485 approval time seems to have increased, which will partly offset the the higher numbers.

Header updated.

Basically EB3 is showing very low demand and EB2 very high. The repurcusions are obvious. EB2I is going to get a bad deal this year. And eB3I might be in for a very nice surprise.

Hello Q,
can you elaborate more on how "bad" the deal could be?
Will we cross May 2009 PD ( From Last Year) or not even get to that?

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Originally Posted by qesehmk

Header updated.

Basically EB3 is showing very low demand and EB2 very high. The repurcusions are obvious. EB2I is going to get a bad deal this year. And eB3I might be in for a very nice surprise.

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Originally Posted by aquatican

Hello Q,
can you elaborate more on how "bad" the deal could be?
Will we cross May 2009 PD ( From Last Year) or not even get to that?

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aquatian - I hope I am wrong. But I believe we will not cross that.

That is so disappointing. I was hoping to get EAD this year ( PD Jun 19 , 2009 ).
I guess it will be very clear by next couple of bulletins and Inventory release how far into 2009 ( If at all) the PD is going to go this year.

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Originally Posted by qesehmk

aquatian - I hope I am wrong. But I believe we will not cross that.

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Originally Posted by aquatican

That is so disappointing. I was hoping to get EAD this year ( PD Jun 19 , 2009 ).
I guess it will be very clear by next couple of bulletins and Inventory release how far into 2009 ( If at all) the PD is going to go this year.

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Now that nobody knows. DOS can still move dates back and forth violently just to take a fresh intake of applications even if they do not have the numbers to justify the movement.

So I wouldn't rule that out. I was only talking about ability to get a GC.

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Originally Posted by qesehmk

aquatian - I hope I am wrong. But I believe we will not cross that.

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Q, I don't understand fully. Do you mean to say that even May 1 2009 will not be met this year. Mine is April 17 2009 and I filed 485 last year and was hoping to get GC this year. Is there a possibility that May 2009 will also not hit this year?

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Originally Posted by saagar_is_cool

Q, I don't understand fully. Do you mean to say that even May 1 2009 will not be met this year. Mine is April 17 2009 and I filed 485 last year and was hoping to get GC this year. Is there a possibility that May 2009 will also not hit this year?

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Sagar dates hitting May 2009 doesn't guarantee a GC. They should hit there and stay for 3-4 months at least. So I do not believe that's going to happen.

I am sorry but the key reason why I think that's how it will be is that EB2ROW is on a tear. 160-170% increase in consumption compared to last year. So EB2I is only going to depend on EB1 / 4 / 5 - none of which I am very hopeful about.

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Originally Posted by qesehmk

Sagar dates hitting May 2009 doesn't guarantee a GC. They should hit there and stay for 3-4 months at least. So I do not believe that's going to happen.

I am sorry but the key reason why I think that's how it will be is that EB2ROW is on a tear. 160-170% increase in consumption compared to last year. So EB2I is only going to depend on EB1 / 4 / 5 - none of which I am very hopeful about.

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160-170% increase - based on trackitt data or some other source?

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Originally Posted by qesehmk

Sagar dates hitting May 2009 doesn't guarantee a GC. They should hit there and stay for 3-4 months at least. So I do not believe that's going to happen.

I am sorry but the key reason why I think that's how it will be is that EB2ROW is on a tear. 160-170% increase in consumption compared to last year. So EB2I is only going to depend on EB1 / 4 / 5 - none of which I am very hopeful about.

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Last year EB2ROW used 19K GC's even with 160% increase, it will be 31K EB2ROW + 3K EB2C = 34k and EB2I will still receive (41 - 34) 7K+ from EB2 quota. If we do get some spillover which we should EB2I will receive 10-12K GC's. ( I think 160% increase is the worst case scenario but cannot be ruled out).

The good thing is EB3I will move substantially this year and next and will provide some relief to EB2I.

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Originally Posted by redwood

Last year EB2ROW used 19K GC's even with 160% increase, it will be 31K EB2ROW + 3K EB2C = 34k and EB2I will still receive (41 - 34) 7K+ from EB2 quota. If we do get some spillover which we should EB2I will receive 10-12K GC's. ( I think 160% increase is the worst case scenario but cannot be ruled out).

The good thing is EB3I will move substantially this year and next and will provide some relief to EB2I.

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That 19 k was for EB2-ROW alone, which does not count use by Mexico and Philippines.

EB2-WW (EB2-non IC) used 22k last year.

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Originally Posted by redwood

Last year EB2ROW used 19K GC's even with 160% increase, it will be 31K EB2ROW + 3K EB2C = 34k and EB2I will still receive (41 - 34) 7K+ from EB2 quota. If we do get some spillover which we should EB2I will receive 10-12K GC's. ( I think 160% increase is the worst case scenario but cannot be ruled out).

The good thing is EB3I will move substantially this year and next and will provide some relief to EB2I.

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Plus I am assuming 160% increase is based on trackitt data. So I would not take that dollar to dollar.
IMO- EB2I will most certainly hit Q3 2009 if not more. How many of those get GC this year is a different discussion.

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Originally Posted by Spectator

My best stab at a comparison of PERM Certifications between FY2014 and FY2015 for Q2 and H1 (Q1/Q2).

-------------- FY14 Q2 - FY15 Q2 - % of FY14
China ---------- 1,188 --- 1,645 ---- 138%
India ---------- 9,446 -- 12,611 ---- 134%
Mexico ----------- 321 ----- 386 ---- 120%
Philippines ------ 474 ----- 319 ----- 67%
ROW ------------ 5,679 --- 5,217 ----- 92%

ALL ----------- 17,108 -- 20,178 ---- 118%


-------------- FY14 H1 - FY15 H1 - % of FY14
China ---------- 1,829 --- 3,074 ---- 168%
India --------- 14,522 -- 21,820 ---- 150%
Mexico ----------- 602 ----- 681 ---- 113%
Philippines ------ 684 ----- 635 ----- 93%
ROW ------------ 8,535 -- 10,160 ---- 119%

ALL ----------- 26,172 -- 36,370 ---- 139%


This is a comparison of the preceding rolling yearly PERM Certification numbers for the preceding year and this year i.e. Q3 FY2013 to Q2 FY2014 and Q3 FY2014 to Q2 FY2015.

------------- H2FY13/H1FY14 -- H2FY14/H1FY15 - %
China ---------- 2,631 ---------- 5,822 ----- 221%
India --------- 23,099 --------- 42,390 ----- 184%
Mexico ----------- 861 ---------- 1,374 ----- 160%
Philippines ---- 1,056 ---------- 1,453 ----- 138%
ROW ----------- 12,600 --------- 21,792 ----- 173%

ALL ----------- 40,247 --------- 72,831 ----- 181%

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Thanks Spec!

Any pointers about change in EB2:EB3 mix(ROW)? Do you think rapid EB3-ROW movement might have changed mix by a fair percentage?

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Originally Posted by suninphx

160-170% increase - based on trackitt data or some other source?

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Trackitt as well as PERM.

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Originally Posted by Spectator

That 19 k was for EB2-ROW alone, which does not count use by Mexico and Philippines.

EB2-WW (EB2-non IC) used 22k last year.

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Thanks for the clarification, Spec. Oh well, this is the armageddon scenario we have been dreading but have been dodging all these years. I guess if PERM doesn't slow down considerably or some legislative relief, this is the likely scenario every year. Absent that lets hope relief comes from major EB3I spillover and EB2I folks downgrading to EB3I.

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Originally Posted by qesehmk

Sagar dates hitting May 2009 doesn't guarantee a GC. They should hit there and stay for 3-4 months at least. So I do not believe that's going to happen.

I am sorry but the key reason why I think that's how it will be is that EB2ROW is on a tear. 160-170% increase in consumption compared to last year. So EB2I is only going to depend on EB1 / 4 / 5 - none of which I am very hopeful about.

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Q, I am not sure if I am missing something here. If the date hits May 2009 in June/July and stays current for about 3 months, why would I not get a GC, assuming there are no RFE's. For first time filers, I can understand but if I filed in last September, is there a reason why GC wont come. Is there something one can do to influence the movement - Senator/congressman, Ombudsman, SR etc. ?

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Originally Posted by saagar_is_cool

if the date hits May 2009 in June/July and stays current for about 3 months,

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then you have a good chance. Yes.

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Originally Posted by suninphx

Thanks Spec!

Any pointers about change in EB2:EB3 mix(ROW)? Do you think rapid EB3-ROW movement might have changed mix by a fair percentage?

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suninphx,

Good question!

The honest answer is that I don't know. The information available isn't that good.

Possibly an analysis of the Employer/Job in PERM or the PWD data might shed some light on it, but I haven't done that.

I wouldn't be surprised if the EB3-M numbers have shifted towards EB3. There also has to be a danger that EB3-P numbers will ramp up now that the dates are effectively Current and the wait times are fairly short. That generally wouldn't show in the PERM figures, since the highest demand will be from Schedule A nurses and PT. With shorter wait times, the abandonment rate for EB3-P will probably drop.

I'm not sure whether that will effect this FY or not.

The USCIS Inventory data will become less useful for determining EB3-WW numbers. The I-140 needs to be approved for the I-485 to be included in the figures, so increasingly, cases won't show.

Trackitt data (I know you aren't a great fan) suggests EB3-ROW approvals have reached a PD of about Sept 2012 (with a couple of later outliers). That's only where the COD was in the April/May 2014 VB , before retrogression. The COD only moved past that again in November 2014. I-485 seem to be taking about 7 months to approve at this point. That's possibly why we are seeing a lull in EB3-ROW approvals currently.

I'm a little more optimistic than some others and there is still almost half the year to go. That said, I don't believe it will be a particularly good year for EB2-I.

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Originally Posted by qesehmk

Header updated.

Basically EB3 is showing very low demand and EB2 very high. The repurcusions are obvious. EB2I is going to get a bad deal this year. And eB3I might be in for a very nice surprise.

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Hi Q,

Any hint how much SO EB3I might receive? Any guesstimate? Really appreciate your analysis.

Thanks
Amul

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Originally Posted by qesehmk

Sagar dates hitting May 2009 doesn't guarantee a GC. They should hit there and stay for 3-4 months at least. So I do not believe that's going to happen.

I am sorry but the key reason why I think that's how it will be is that EB2ROW is on a tear. 160-170% increase in consumption compared to last year. So EB2I is only going to depend on EB1 / 4 / 5 - none of which I am very hopeful about.

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i know that at one point it was said that the eb2-I dates should (could?) go to Q4 2009. Is that not looking possible now? My PD is 30Oct2009. I am asking because of being selfish and trying to see if I can at least get a chance to file 485 this year.

It is frustrating that it is not even PD+6 years anymore.

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Originally Posted by amulchandra

Hi Q,

Any hint how much SO EB3I might receive? Any guesstimate? Really appreciate your analysis.

Thanks
Amul

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I do not do manual calculations anymore Amul. So the honest answer is i don't know unless I login to whereismygc and run a scenario for EB3I.

But looking at the macro picture I am very comfortable in predicting that EB3I dates are going to move like never before. The movement we have seen is just scratching the surface!

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Originally Posted by 4WatItsWorth

It is frustrating that it is not even PD+6 years anymore.

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There is a reason why it has come to that. And the reason is - over years EB3ROW demand has shifted to EB2ROW. And so has a lot of EB3I demand. Thus EB2 is getting clobbered while EB3 is getting into a good spot.