Public Comments / Sign-on Letters

The Immigrant Legal Resource Center created this template to help you draft your own comments in opposition to this interim rule with request for comment. The new rule can be found here. Comments are due by October 25, 2019.  We are very concerned about this rule’s “reorganization” at EOIR that eliminates OLAP, the office that has operated the Recognition and Accreditation (R & A) Program  and the legal orientation programs until now. The rule places the  remaining functions of OLAP under an Office of Policy.
On June 5, 2019, the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) published a third notice regarding its plans to dramatically change fee waiver eligibility and process. The June 5 notice attempts to provide additional justification for its plan to eliminate means-tested benefits as a basis for requesting a fee waiver, among other changes, following April 5 and September 28 notices that lacked rationale for why such changes to fee waivers are justified. Now, USCIS is also claiming lost fee revenue as a reason for its proposed changes to fee waivers, making clear its intention to reduce the number of fee waivers that are granted. If finalized, these proposed changes will discourage eligible individuals from filing for fee waivers and immigration benefits and place heavy time and resource burdens on those who do still apply for fee waivers.