dissenting.
I must respectfully dissent. In the survey conducted by the Secretary, wage data pertaining to publicwork projects was excluded because it did not reflect freely negotiated or market rates, but instead were rates arbitrarily imposed by law. If these public work projects were included in the survey, then the artificially set rates would skew its results, and impede the Secretary’s efforts to implement a fundamental policy change to a more accurate system of determining those wage rates which actually are “prevailing” in the particular time and place. Under these circumstances, the exclusion of public work projects is a legitimate exercise of the Secretary’s broad discretion. The majority recognizes the well-established principle that:
An interpretation by the agency charged with a statute’s implementation is accorded great weight and will be overturned only if such a construction is clearly erroneous.
Cherry v. Pennsylvania Higher Education Assistance Agency, 537 Pa. 186, 188, 642 A.2d 463, 464 (1994). Nonetheless, it ignores the Secretary’s interpretation of 34 Pa.Code § 9.105(d) in favor of that proffered by the petitioners. The language in question states that, “Rates shall be determined for varying types of projects within the entire range of work performed by the building and construction industry.” The Secretary’s inter*1145pretation is that this “sentence speaks to the types of projects for which the Secretary must issue wage rates — not the type of projects from which he must collect data.” [Brief at 34, n.25] [emphasis added]. While I believe reasonable minds might differ in their reading of this provision, I cannot say that the Secretary’s interpretation is less reasonable than that accepted by the majority. I certainly cannot characterize the Secretary’s view as clearly erroneous.
Moreover, having interpreted the regulation to require the collection of data from “varying types of projects within the entire range of work performed in the.. .industry,” it reads that language to mean an adequate sample from each and every type of project within the industry. The majority then substitutes its judgment for that of the Secretary and the Prevailing Wage Board to determine that an inadequate sample was collected with respect to two specific types of building projects — highways in the non-residential private sector and sewage treatment plants. The majority opines:
The Secretary’s decision not to gather wage information from public highway and sewage treatment projects will certainly result in prevailing wages for such new construction being calculated using data derived from small, unrepresentative types of private projects, or from a very limited sampling of private large-scale undertakings. This Court can envision scenarios where the Secretary would calculate the wages for workers building a highway using survey data that was generated by contractors who build short private roads or parking lots, or set the wages for workers building a major metropolitan sewage treatment plant using data collected from contractors engaged in the construction of wastewater facilities in a private home development.
Op. at 1143. The very language employed by the majority reflects the subjective and speculative nature of its conclusions. Even if the regulation is read to require that each subcategory of work be represented by an adequate quantity of data in the survey, it is for the Secretary, not this court, to determine what is “representative” of the various types of projects. Again, even if I were persuaded that the majority had the better view of the issue, that is not the question. Rather, as the majority notes, it is whether the Secretary’s determination is arbitrary or capricious. Bandy v. Commonwealth, 108 Pa. Cmwlth. 387, 530 A.2d 507, 511 (Pa.Cmwlth.1987), petition for allowance of appeal denied, 518 Pa. 614, 540 A.2d 535 (1988). Because I do not believe that the Secretary abused his discretion, I would affirm in all respects.1
. Moreover, even if the perceived inadequacies in the data relating to construction of major highways and sewage treatment plants amounted to an abuse of discretion, I can see no basis for overturning the Secretary’s determinations of all prevailing wages rather than simply the prevailing wages on those two categories of projects.