Public Comments / Sign-on Letters

On October 19, 2022, USCIS published major revisions to their Policy Manual on the English and/or Civics disability waiver for naturalization applicants. Overall, these changes were a welcome improvement in access to the disability waiver. However, we opposed the sections in the revised Policy Manual and N-648 that add a question about understanding the oath of allegiance. The oath waiver and the...
Texas-based attorneys Priscilla Olivarez and Jennefer Canales-Pelaez submitted these comments to the Texas Senate Border Committee. The committee heard testimony on Nov. 15, 2022 on whether to fund Operation Lone Star in the future and the role of the state's Department of Public Safety.
ILRC wrote a letter to USCIS to commend the agency on the October 19, 2022 USCIS announcement of major revisions to the Form N-648, Medical Certification for Disability Exceptions. This form is used by naturalization applicants who are seeking a waiver of the English and/or civics requirement based on a disability or impairment that causes the applicant to be unable to learn or demonstrate...
Sample questions about the sheriff’s policy positions on working with ICE that advocates or community members can use at candidate forums or other meetings. For more background information about sheriffs and their role in the deportation pipeline, see:
ILRC commended USCIS on its recent extension of COVID flexibility policies through October 23, 2022. In addition, we suggested some new COVID-related policies to ameliorate the impact of the pandemic, including longer extensions of time to respond to notices and decisions, adoption of a mailbox rule for filing deadlines, and allowing waivers to proceed despite death of a qualifying relative.
ILRC commends USCIS on the recent USCIS Policy Manual additions clarifying guidance on the unlawful presence bars. We further thank USCIS for rescinding Matter of Z-R-Z-C and updating its interpretation on the effects of authorized travel by Temporary Protected Status (TPS) beneficiaries. These changes will benefit affected applicants significantly, create clarity and consistency across...
On July 14, 2022, the ILRC submitted a comment to USCIS about Form N-400, Application for Naturalization. ILRC requested that USCIS revise Form N-400 to be shorter and to request information that is only relevant to eligibility for naturalization. ILRC also encouraged USCIS to do away with its practice of re-adjudicating underlying forms at the naturalization stage – a practice that is burdensome...
The ILRC submitted a comment to USCIS requesting that USCIS clarify who may file an N-600K, Application for Citizenship and Issuance of Certificate Under Section 322, and to prioritize applications for children who are close to turning eighteen and aging out of elibiblity for citizenship under INA Section 322.
The ILRC submitted a comment to USCIS in support of the agency’s temporary increase of 540 days for the validity periods for Employment Authorization where an EAD renewal application is pending. This move will help provide financial stability for those who rely on authorization for employment and are currently stuck waiting in long processing backlogs.


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