Public Comments / Sign-on Letters

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: https://www.ilrc.org/role-sheriffs-and-arrest-deportation-pipeline
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.
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 in time and resources and discourages eligible Lawful Permanent Residents from engaging with the naturalization process.
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.
On June 6, 2022, the ILRC submitted a comment on USCIS Form I-765, Application for Employment Authorization.  The comment encourages USCIS to amend the form to be shorter, to eliminate unnecessary questions, and to provide clarification where needed. The comment also asks USCIS to withdraw the discretionary factors used to adjudicate the form.
On May 5, 2022, ILRC, AILA, and AIC jointly filed a comment to USCIS’s revisions to the G-639 FOIA Request form. We suggested changes to the proposed revisions to the Form G-639 Instructions regarding the online filing of FOIA through the agency’s FIRST system. The online system should not require country of birth and other identity information that is not needed in filing a written G-639 request. Also, the Instructions should clearly state FIRST is one option among others for submitting a FOIA request.
The ILRC and partner organizations submitted the attached letter and BIA case summary to OPLA leadership, clarifying that vacaturs issued pursuant to California Penal Code § 1473.7(a)(1) correct legally and procedurally defective convictions, meeting the standard set forth in Matter of Pickering, 23 I&N Dec. 621 (BIA 2003).