Public Comments / Sign-on Letters

The Immigrant Legal Resource Center (ILRC) submitted a comment to USCIS opposing proposed changes to Form I-130, which would more than double the form’s length and require additional information from petitioners and beneficiaries, including expanded criminal history, employment, education, and family-history questions.
The Immigrant Legal Resource Center (ILRC) submitted a comment strongly opposing the Department of Homeland Security’s Final Rule on “[Immigrant] Registration Form and Evidence of Registration.” The rule expands and formalizes a registration process that could expose millions of immigrants—and potentially U.S. citizens—to increased fear, confusion, racial profiling, and immigration enforcement.
On June 29, 2026, the Immigrant Legal Resource Center (ILRC) submitted comments urging USCIS to withdraw its proposed revisions to Form N-648, the Medical Certification for Disability Exceptions used by naturalization applicants seeking a waiver of the English and civics requirements based on disability. ILRC commented that the proposed revisions unlawfully impose new eligibility standards that are not authorized by the Immigration and Nationality Act, federal regulations, or USCIS's own Policy Manual.
The Immigrant Legal Resource Center (ILRC) submitted comments opposing the Department of Homeland Security's proposed rule to increase the filing fee for Form I-246, the Application for a Stay of Deportation or Removal, from $155 to $755. The comment provides that the proposed 387% fee increase is arbitrary and capricious under the Administrative Procedure Act because DHS fails to provide a reasoned justification for the increase or adequately consider its devastating impact on immigrants seeking protection from deportation.