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.
The rule amounts to much more than an internal reorganization and will have substantive impact on OLAP’s legal access programs. The Office of Policy was organized by the Attorney General within EOIR in 2017 and has demonstrated its intent to comply with the administration’s agenda on immigration. The reorganization signals a retreat from legal access programs and is an ill-disguised effort to eliminate them.
You may receive several template comments from different organizations, and we encourage you to use the template or template sections of your choice and to mix and match.
Comments should be submitted online to www.regulations.gov, or by mail to Lauren Alder Reid, Assistant Director, Office of Policy, Executive Office for Immigration Review, 5107 Leesburg Pike, Suite 2616, Falls Church, VA. 22041. If filing online, click on “comment now” and either enter your comment in the text box (must be fewer than 5000 characters) or upload your comments as a PDF. As you are drafting your comment, here are some important tips to keep in mind.
Write comments in your own words. Agency staff must code and organize all comments, and the process is very different if they must pause and consider what’s similar and what’s different in each comment, as opposed to just counting the number of commenters saying the same thing. It’s fine to work from a sample comment, but you should modify it to reflect your own thoughts and experiences so that it counts as a unique comment. Directions in YELLOW indicate sections that you should customize as you create your comment.
Here are a few recommended approaches.
- Please explain your expertise and cite relevant research when talking about the impact that it would have on your program and the immigrants you serve if the legal access programs under OLAP are politicized or eliminated, which this “reorganization” portends.
- If you work directly with immigrants, please describe why they usually come to the country, how they need low cost legal services from R & A programs, and how your program and the immigrants you serve benefit from the legal orientation programs run by OLAP.